Case Analysis: Rollymol vs State of
Kerala
• A Deep Dive into Criminal Investigation and
Legal Provisions in India
• March 20, 2025
Introduction
• • Examination of the Rollymol vs State of
Kerala case
• • Insights into the criminal investigation
process in India
• • Discussion on scientific investigation
methods and legal provisions
Case Background
• • Defendant: Rollymol, accused of filicide
• • Incident Location: Kerala, India
• • Initial Charge: Murder under Section 302 IPC
Trial Court Proceedings
• • Outcome: Conviction under Section 302 IPC
• • Sentence: Life imprisonment
• • Basis: Circumstantial evidence and witness
testimonies
Appeal to the Kerala High Court
• • Grounds for Appeal:
• - Failure to assess the mental state of the
accused
• - Reliance on inadequate investigation
• • Appellant’s Argument: Investigation was
flawed due to lack of scientific methods
High Court’s Observations
• • Investigating officer filed the charge sheet
without ascertaining the mental state of the
accused
• • This reflects a dishonest approach, making
the charge sheet defective
Acquittal Decision
• • Judgment Date: December 17, 2024
• • Outcome: Conviction and sentence under
Section 302 IPC set aside
• • Reasoning: Defective investigation and lack
of evidence on the accused's mental state
Importance of Mental State
Assessment
• • Legal Provision: Section 84 IPC - Act of a
person of unsound mind
• • Implication: Accused cannot be held liable if
incapable of understanding the nature of the
act
Role of Scientific Investigation
• • Definition: Application of scientific methods
to gather and analyze evidence
• • Significance: Enhances accuracy and
reliability in criminal investigations
• • Challenges: Lack of resources and trained
personnel in India
Forensic Science in India
• • Evolution:
• - Introduction of DNA technology
• - Advancements in fingerprint analysis
• • Impact: Improved crime detection and
conviction rates
Legal Framework Governing
Investigations
• • Indian Penal Code (IPC): Defines offenses
and punishments
• • Code of Criminal Procedure (CrPC): Lays
down the procedure for investigation
• • Indian Evidence Act (IEA): Regulates
admissibility of evidence
IPC Provisions Relevant to
Investigation
• • Section 302: Punishment for murder
• • Section 84: Act of a person of unsound mind
• • Section 300: Definition of murder
CrPC Provisions Relevant to
Investigation
• • Section 154: Information in cognizable cases
• • Section 173: Report of police officer on
completion of investigation
• • Section 161: Examination of witnesses by
police
IEA Provisions Relevant to
Investigation
• • Section 45: Opinions of experts
• • Section 27: How much of information
received from accused may be proved
• • Section 3: Defines evidence
Challenges in Scientific
Investigation
• • Issues:
• - Limited infrastructure
• - Shortage of trained forensic experts
• - Delays in evidence analysis
• • Consequences: Compromised quality of
investigations
Case Study: Impact of Defective
Investigation
• • Example: Rollymol vs State of Kerala
• • Outcome: Acquittal due to improper
investigation
• • Lesson: Need for thorough and scientific
investigative methods
Recommendations for
Improvement
• • Suggestions:
• - Enhance training for investigating officers
• - Upgrade forensic laboratories
• - Implement standard operating procedures
Role of Judiciary in Promoting
Scientific Investigation
• • Actions:
• - Encouraging use of forensic evidence
• - Critiquing inadequate investigations
• • Impact: Promotes accountability and
accuracy
Public Perception and Trust
• • Current Scenario: Skepticism due to flawed
investigations
• • Need for Reform: Strengthen legal
framework and forensic capabilities
Conclusion
• • The case highlights the importance of
scientific investigation in criminal justice
• • Courts must emphasize fair trials and
evidence-based prosecution
• • Strengthening forensic infrastructure is
crucial for justice delivery
