Bench affirms life sentence, stressing parental duty to care for children and rejecting hardship as justification for taking a life.
Madras High Court: A Division Bench of the Madras High Court comprising Justices G.K. Ilanthiraiyan and R. Poornima delivered the judgment on 13 February 2026.
Case Title & Procedural Posture
In S. Muneeswaran & Anr v. State represented by Inspector of Police, Malli Police Station, the High Court heard a criminal appeal filed by parents convicted of murdering their nine-year-old daughter by administering pesticide. The parents had challenged the convictions and sentences imposed by the Fast Track Mahila Court, Virudhunagar.
Background of the Case
According to prosecution evidence, the couple’s daughter was born in May 2009 with a significant mental disorder requiring full-time care. The child’s mother resigned from her academic position to care for her. Over time, the family faced severe psychological and financial strain.
On 1 October 2018, the parents allegedly took the child to the Kathappasamy Temple in Virudhunagar and mixed Tafgor, an organophosphorus pesticide, with a cool drink given to her. Passersby noticed her distress and intervened. The girl was taken to a local hospital and then to Government Rajaji Hospital, Madurai, where she died five days later on 6 October 2018.
Police registered a First Information Report and the trial court convicted both parents under Sections 302 (murder) and 342 (wrongful confinement) of the Indian Penal Code, sentencing them to life imprisonment and fines.
Legal Issues
The High Court’s review focused on:
- Whether the evidence before the trial court and at the appeal stage sufficiently established that the death resulted from poisoning administered by the parents.
- Whether a negative chemical analysis in the viscera report undermined the prosecution’s case.
- The applicability of parental hardship as a mitigating circumstance in cases of filicide.
High Court’s Ruling
The Bench dismissed the appeal, upholding both the conviction and life sentences imposed on the couple. It held that the trial court’s findings were neither perverse nor illegal.
Court’s Reasoning (Brief)
Evidence and Admissions:
The High Court noted that the child was in the exclusive custody of her parents at all relevant times and that both had admitted to hospital staff that they administered poison. This admission was recorded in the Accident Register. Witness testimony and clinical signs, such as constricted pupils and respiratory distress, were consistent with organophosphorus poisoning.
Negative Viscera Report:
Addressing the argument that the viscera analysis did not detect poison, the Court relied on established legal principles that a negative chemical report is not automatically fatal to the prosecution’s case, especially where the victim survived for several days after ingestion and received medical treatment. Poisons can metabolise or decompose, making chemical detection difficult. In such instances, greater weight is placed on clinical diagnosis and testimony of treating doctors.
Parental Duty and Hardship:
While expressing sympathy for the difficulties faced by the parents, the Bench emphasised that it is a “bounden duty” for parents to care for their children, regardless of mental or physical disabilities. The Court underlined that no person has the right to take the law into their own hands and extinguish another life, and personal hardship cannot justify such an act.
The bench observed that allowing parental hardship to justify filicide would endanger every child born with disabilities, thereby undermining fundamental protections under criminal law and constitutional guarantees of the right to life.
Practical Implications
- The judgment reinforces the principle that parental hardship or emotional distress is not a legal defence to homicide, particularly in disability-related filicide cases.
- It clarifies that clinical evidence and admissions by the accused can outweigh negative forensic reports in poisoning cases.
- The decision may guide future courts on the interplay between evidentiary requirements and medical expert testimony in complex homicide appeals.
- It underscores the judiciary’s firm stance on upholding rights of vulnerable dependents, affirming that disability does not diminish the state’s duty to protect life.
The judgment adds clarity on the standards for evaluating circumstantial and medical evidence in poisoning cases and affirms that parental duty to care for a child, regardless of disability, cannot be displaced by personal hardship or emotional distress.
