C Kamalakkannan vs The State of Tamil Nadu (2025) - Case Analysis

Why in the Spotlight? - C Kamalakkannan vs The State of Tamil Nadu (2025)

The legal proceedings in C Kamalakkannan vs The State of Tamil Nadu (2025) became notable because it examined expert testimony admissibility in criminal courts. The case challenged the ability to sustain a conviction based only on handwriting expert testimony in the absence of the original document as evidence. The decision of the Supreme Court bolstered the importance of primary evidence in forgery cases. The case set an important precedent for future trials. Discover more in-depth analyses of important Supreme Court decisions by exploring Recent Judgements of Supreme Court

The recent case of C Kamalakkannan vs The State of Tamil Nadu (2025) centres around the allegations of forgery in an MBBS admission procedure. The Appellant was convicted under Section 120B, Section 468 and Section 471 of Indian Penal Code based on the opinion of the handwriting expert. The main question which was addressed by the Supreme Court was whether a conviction could be sustained solely on expert testimony without the original document as evidence.

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Historical Context and Facts of C Kamalakkannan vs The State of Tamil Nadu (2025)

The case at hand centred on the forgery of a marksheet for MBBS admission, leading to the conviction of the Appellant under Section 120B, Section 468 and Section 471 of Indian Penal Code. The following are the brief facts of the case of C Kamalakkannan vs The State of Tamil Nadu -

Conviction by the Trial Court

The Appellant filed an appeal by special leave and challenged his conviction in Calendar Case No. 279 of 2011, decided by the Judicial Magistrate No. 1, Thiruvallur. He was found guilty under various Sections of Indian Penal Code: Section 120B, Section 468 and Section 471.

On October 25, 2016, the Trial Court convicted the Appellant and other co-accused. The Appellant was sentenced to -

• Imprisonment already undergone as an undertrial (October 22, 1996 – November 16, 1996)
• Fine of Rs. 1,000 under Section 120B IPC
• Fine of Rs. 1,000 under Section 468 IPC
• Fine of TRs. 2,000 for two counts under Section 471 IPC
• Default sentence: Two months of simple imprisonment in case of non-payment of the fine

Appeal Before the Sessions Court

Aggrieved by this, the Appellant challenged his conviction before the Principal Sessions Judge, Thiruvallur. On October 23, 2017, the Appellate Court upheld the judgment of the Trial Court but reduced the fine to Rs. 600 for each count under Sections 120B, 468, and 471 IPC. However, the default imprisonment of two months remained unchanged.

Revision Petition Before the High Court

Dissatisfied with the decision of the Appellate Court, the Appellant filed a revision petition before the High Court of Judicature at Madras. On April 16, 2019, the High Court dismissed the petition and confirmed the conviction and sentence. The Appellant challenged this decision in the Supreme Court.

Background of the Case

The case originated when Kumari Amudha applied for admission to an MBBS course using a forged marksheet. She had actually scored 767 marks out of 1200, the marksheet she submitted falsely showed 1120 out of 1200 marks.

A criminal case was registered which led to an investigation and charge sheet against the Appellant and other co-accused. As a result, he was convicted and both his appeal and revision petition were dismissed.

The primary issue in C Kamalakkannan vs The State of Tamil Nadu (2025) was whether a conviction can be sustained based solely on a handwriting expert opinion when the original document in question was not presented as evidence?

Legal Provisions involved in C Kamalakkannan vs The State of Tamil Nadu (2025)

In C Kamalakkannan vs The State of Tamil Nadu (2025) Section 120B, Section 468 and Section 471 of Indian Penal Code and Section 45 of Indian Evidence Act played a significant role. The following are the analysis of these provisions -

Section 120B of Indian Penal Code: Punishment for Criminal Conspiracy

Section 120B provides punishment for Criminal Conspiracy (Now Section 61 of Bharatiya Nyaya Sanhita 2023). It penalizes individuals who conspire to commit an offence. The Prosecution alleged that the Appellant was part of a conspiracy to fabricate a mark sheet for MBBS admission.

Section 468 of Indian Penal Code: Forgery for the Purpose of Cheating

Section 468 of Indian Penal Code is applicable when a person forges a document intending to deceive or gain an unlawful advantage. In C Kamalakkannan vs The State of Tamil Nadu the Appellant was accused of forging a mark sheet to show inflated marks.

Section 471 of Indian Penal Code: Using a Forged Document as Genuine

Section 471 of Indian Penal Code states that anyone who knowingly uses a forged document as if it were genuine can be punished. The Prosecution in this case argued that the Appellant used the fake mark sheet for admission.

Section 45 of the Indian Evidence Act, 1872: Expert Opinion

Section 45 (Now Section 39 of Bharatiya Sakshya Adhiniyam, 2023) permits the courts to consider expert testimony on matters requiring specialized knowledge such as handwriting analysis. The case hinged on whether the handwriting expert’s opinion, without the original document, was sufficient to convict the Appellant.

Judgment and Impact of C Kamalakkannan vs The State of Tamil Nadu (2025)

The 2-Judge Bench of the Supreme Court comprising Justice Vikram Nath and Justice Sandeep Mehta in C Kamalakkannan vs The State of Tamil Nadu highlighted that expert testimony does not always require corroboration, the Courts must exercise caution when relying on handwriting experts due to the inherent limitations of handwriting analysis.

The Prosecution presented a handwriting expert's opinion to establish that the Appellant’s handwriting appeared on a postal cover. The prosecution failed to show the original postal cover as evidence which left its existence unverified. The Appellant argued that without the original document the expert’s report lacked credibility.

Findings of the Supreme Court

The Supreme Court in C Kamalakkannan vs The State of Tamil Nadu held that the Prosecution failed to establish the existence of the conflicted postal cover, which was primary to the case. The Court also referred to the landmark judgement of Murari Lal v. State of M.P. (1980) where it was stated how the courts should assess expert opinions under Section 45 of Indian Evidence Act.

The Supreme Court stated the following principles:

• Expert evidence is not inherently unreliable but must be cautiously examined.
• There is no rule that handwriting expert opinions must always be corroborated.
• Given the imperfect nature of handwriting identification, courts should exercise caution and consider other relevant evidence.

Reasoning for Acquittal

The Supreme Court in C Kamalakkannan vs The State of Tamil Nadu observed that -

• Since the postal cover was never exhibited or proven in evidence, the handwriting expert’s opinion lost its evidentiary value.
• Without proving the existence of the postal cover, the prosecution’s theory that it contained the appellant’s handwriting could not be accepted.

Thus, the Supreme Court set aside the conviction and held that the Appellant was entitled to an acquittal.

Conclusion

In C Kamalakkannan vs The State of Tamil Nadu (2025) the Supreme Court adjudicated in favor of the Appellant. The Court highlighted that expert opinions are valuable but must be scrutinized, especially in cases when the primary evidence is missing. The Court held that the Prosecution failed to establish its case beyond a reasonable doubt. As a result, the conviction of the Appellant was set aside.