First Information Report

(Under section 154 Cr. P. C)

District : Thiruvananthapuram

Police Station : Medical College

Thiruvananthapuram

F. I. R. No : 124/2020

Date and Time of F. I. R : 15/06/2020, 12:00 PM

Occurrence of Offence :

Time :

Information received at
Police Station : 15/06/2020, 10:00 AM

Place of occurrence (Direction and Distance) : Near Neyyar Dam, East – 5 KM

Complainant / Informant : Suresh (Informant)

Father’s Name : Raghav

Date / Year of Birth : 20th April/ 1985

Address of Informant : SS Nivas, Vellarada

Thiruvananthapuram
 Particulars of accused person charge sheeted

SL No: 1

i) Name : Krishna Kumar

ii) Fathers /Husband Name : Kumar

iii) Date / Year of Birth : 20th May/1992

iv) Sex : Male

v) Passport No / Date of Issue : Nil

vi) Religion : Hindu

vii) Occupation : Business

viii) Address : Lalita Mansion, TC 13/467

Rose Road, Thiruvananthapuram

ix) Date of Arrest : 20/08/2020

x) Date on which forwarded to court : 21/08/2020

xi) Name and Address of : Bail Granted by the Hon’ble

Bailee /Surety Court

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 Particulars of accused person charge sheeted

SL No: 2

i) Name : Dr. Lalita

ii) Fathers /Husband Name : Krishna Kumar

iii) Date / Year of Birth : 05th February /1996

iv) Sex : Female

v) Passport No / Date of Issue : Nil

vi) Religion : Hindu

vii) Occupation : Doctor

viii) Address : Lalita Mansion, TC 13/467

Rose Road, Thiruvananthapuram

ix) Date of Arrest : 20/08/2020

x) Date on which forwarded to court : 21/08/2020

xi) Name and Address of : Bail Granted by the Hon’ble

Bailee /Surety Court

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 FINAL REPORT
(Under Section 173 Cr.P.C.)

1. In the court of : Honorable Judicial First-Class

Magistrate Court III,
Thiruvananthapuram
District : Thiruvananthapuram
Police Station : Medical College, Thiruvananthapuram
FIR No. : 124/2020
Date : 15/06/2020

2. Final Report/Charge Sheet No. : 20/06/2020 – Charge Sheet

3. Date : 20/06/2020

4. Act : IPC
Sections : 34, 302

5. Type of Final Report : Charge Sheet

(Charge Sheeted / untraced / unoccurred
Not Charge sheeted for want of evidence)

6. If F. R. unoccurred : N/A
(False / Mistake of Fact / Mistake of Law /
Non-cognizable / Civil nature)

7. If original or supplementary : Original

8. Name, Rank, and Number (if any) : Narayan, Circle Inspector of Police,
of the investigation Officer(s) Medical College, Thiruvananthapuram

9. (a) Name of complainant / informant : Suresh (informant)

(b) Father’s / Husband name : Raghav (Father)

10.Details of Recovery : Pair of shoes used by the first accused

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 Witnesses Points to be proved

1 Suresh S/O Raghav, That he spotted the dead body of a male near his
SS Nivas, Vellarada workplace on the banks of Neyyar River and he
informed the same to the Police

2 Radhakrishna Nair, That he was working as gateman cum gardener in

S/O Kunjusankaran, the
KM House, Peroorkkada house of the accused and on 15/06/2020 the
deceased
reached into the house of accused at about 12:30
AM,
that about 2:30 AM accused left from the house
without permitting him to open the gate and at about
3 AM accused returned to the house.

3 Mini, D/O Rajan That she was the servant of the accused, Along with
Vadakkevilakom, Mini, and she know that first accused borrowed
Vembayam huge
amount from the deceased and there were frequent
quarrels in the house regarding the same and to
avoid
her on the crucial day she was given 2 weeks’ leave
and 1-month salary in advance.

4 Shanti w/o Bhaskar, That she was the servant of the accused and was
Shanti Bhavan, home
Ananad, Pattom at the time of the murder with Mini and both the
accused and can verify the same.

5 Nirma, D/O Geroge That she is the company secretary of the deceased
Business Secretary and
R.K. Exports, Palayam, she knows that deceased Raja Mohan lend an
Thiruvananthapuram amount
of Rs 50 Lakhs to the first accused and the amount
is
not repaid.

5
6 Manmohan, That he was working on the car of the accused at the
Lucky Auto Garage, time of the alleged murder and can verify the same
Pattom along with three others at his place of business.

7 Raheem Syed, On 15/06/2020 at about 2:30 AM he intercepted

Sub Inspector of Police, SUV
Traffic – Police Station vehicle KL-01-DC-5678 at PMG Jn and identified
that the accused where travelling in the vehicle.

8 Krishna Das, On 15/06/2020 at about 2:30 AM he was on duty

Police Constable, with
Traffic - Police Station the Sub Inspector of Police and he identified the
accused who are travelling in the vehicle.

9 Dr Margret, That on 16/06/2020 she conducted post mortem of

Associate Professor the
Medical College Hospital deceased and submitted the port mortem report.

10 Jose Abraham, That he registered F. I. R. regarding the death of late

Sub Inspector of Police, Raja Mohan based on the information of CW(1).
Neyyar Dam Police Station
11 Jay Sabu, That he conducted the investigation of the case,
Circle Inspector of Police, interrogated the witnesses, arrested the accused and
Neyyar Dam Police Station submitted charge sheet.



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 FINAL REPORT

That the second accused with an intention to murder the deceased with first
accused so as to escape from the financial liability of Rs 50 Lakh borrowed by
the first accused who is the husband of the second accused, called the deceased
on 15/06/2020 and expressed her desire to have sexual union with him at night
and assured that first accused is out of station for two days. The deceased Raj
Mohan reached into the Mansion of the accused in his Porsche car bearing
register number KL-01-DG-7777 around 12:30 AM. The deceased was invited
by the second accused into her bedroom. After around 5 minutes the first
accused knocked the door. The second accused pretended that they were
trapped hesitantly opened the door. The deceased Raj Mohan in a perplexed
stage knelt down before the first accused holding his leg and beg for mercy.
The first accused with an intention to murder Raj Mohan kicked him with his
shoe firmly on the back of the head. As a result of the same Raj Mohan died
instantly. The second accused who is doctor by profession confirmed the death
of the deceased.

The accused took the dead body of the deceased into the Porsche car. The
first accused drove the Porsche car. The second accused followed the first
accused in her SUV bearing register number KL-01-DC-5678. The first
accused drove the car towards Neyyar Dam which is approximately 20
Kilometres away from the city. The first accused stopped the car in an isolated
place near the banks of Neyyar river and the accused jointly took the dead body
of the deceased and the same was pushed into the river. On the way back the
accused were intercepted by the city night patrol police team at PMG around
2:30 AM. The second accused told the police officials that she is a doctor and
was returning after attending an emergency medical case at the hospital.

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 On receiving information about the dead body of a male aged around 30
years the Sub Inspector of Police reached into the spot conducted inquest and
sent the body for post-mortem examination. The post-mortem report revealed
that the death happened due to the sudden stroke of a thick object and not by
drowning. Hence a case is registered under section 302 IPC and investigation
started.

During investigation the police officers questioned the relatives and friends
of the deceased including the accused. The first accused told to the police that
on that day the accused were in their house throughout. The first accused
further admitted the police that he owned debt of rupees 50 Lakh to the
deceased and expressed his willingness to repay the same to his legal heirs. On
cross checking his statement it is noted that on the crucial day at about 2:30
AM his vehicle was checked by city patrol police and accused were travelling
in the car. The CCTV footage also shows that the said vehicle was travelling
through different points of the city.

Thereafter the accused were thoroughly questioned. Finally, the accused

admitted the fact that they committed the murder to escape from the
consequence of repaying the debt.

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CW_1: Suresh S/O Raghav aged 55 years, SS Nivas, Vellarada

I am a farmer and having 25 cents of cultivated land at Neyyar on the banks of Neyyar river.
On 15/06/2020 at about 8 AM I received phone calls from people at Neyyar that a dead
body was found lying on the bank of Neyyar river adjacent to my property. I rushed from
my house which is 10 Kilometres away from the spot. I cannot identify the dead body. The
people gathered around also cannot identify the body. I informed the police and police
officials rushed into the spot.

Suresh Raghav

CW2: Radha Krishna S/O Sankar aged 50 years, Kunnimala house, Peroorkada,
Thiruvananthapuram

I am the watchman and the gardener of the accused Mr. Krishna Kumar and Lalita Krishna
Kumar from 2017 onwards. I am staying in the outhouse of the mansion of the accused. On
15/06/2020 at about 12:30 AM I opened of the gate of the mansion as instructed by doctor
Lalita and a Porsche car driven by Raj Mohan Sir who was a frequent visitor in the house.
Unusually Raj Mohan Sir did not respond to my greetings and suddenly drove the car inside
the house. At about 2:30 AM I received a phone call from first accused that they were going
outside and for an urgent matter and soon return. When I expressed my readiness, he replied
that he did not want to disturb me. The car returned around 3 AM, I opened the gate and
first accused apologized me for disturbing my sleep. Dr Lalita Madam looked unusually
panic.

Radha Krishna

CW3: Mini aged 52 years D/O Rajan Vadakkevilakom, Vembayam,

Thiruvananthapuram District

I was the servant of Krishna Kumar Sir and Lalita Madam for the last 5 years, along with
Shanti. Both of them are very kind and affectionate towards me. Deceased Raja Mohan sir
was a frequent visitor in the house. Sometimes he visited the house with his wife Anakha
madam and sometimes with his secretary Nirma Madam and sometimes alone. Krishna
Kumar sir is facing financial crisis in his business. There was frequent quarrels in the house
between Krishna Kumar Sir and wife regarding the borrowed amount. Krishna Kumar and
Lalita Madam have no children. On 12/06/2020 Dr Lalita Madam unusually granted me
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 one-month salary in advance and also granted 2 weeks leave to join company with family.
Now I realized that Krishna Kumar sir and Lalita Madam murdered Raja Mohan Sir.

Mini Rajan

CW4: Nirma aged 38 years, D/O George Business Secretary, R.K. Exports, Palayam,
Thiruvananthapuram

I am the business secretary of Raj Mohan Sir. Raj Mohan Sir was an enthusiastic business
man and always valued friendship. Krishna Kumar sir and Raj Mohan sir were classmates
for BBA and MBA courses. Krishna Kumar borrowed Rs 10 Lakhs on 10/03/2017, 20 Lakhs
on 16/03/2018, 25 Lakhs on 15/07/2017 and repaid only Rs 5 Lakhs on 03/03/2020. I
repeatedly reminded my boss about urgently clearing the amount. I have sent 2 letters
reminding Krishna Kumar sir to clear the debt at the earliest. My boss told to me many times
that he is not sure when Krishna Kumar will repay his debt.

Nirmala George

CW5: Raheem Syed aged 37 years, Sub Inspector of Police, Traffic – Police Station

I am the Sub Inspector of Traffic, Pattom, Thiruvananthapuram on 15/06/2020. I was on

patrol duty at about 2:30 AM while I was checking suspected vehicles at PMG Junction, I
noticed an SUV car bearing register number KL-01-DC-5678 was coming from Museum
direction to Pattom direction. I intercepted the vehicle and noticed that one male and female
were sitting in the front seat. I asked them from where they are coming from? The lady
replied that she is a doctor and is returning to her home after attending an urgent medical
case. I found nothing unusual. I just noticed the vehicle number and permitted them to go. I
can recollect the face of the person who travelled in the vehicle.

Raheem Syed

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CW6: Krishna Das aged 39 years, Police Constable, Traffic – Police Station

I am working as Police constable in City Police Traffic, Pattom, Thiruvananthapuram. On

15/06/2020 I was on patrol duty at PMG junction with Sub Inspector of Police, Rahim Sir.
Rahim Sir intercepted a vehicle bearing register number KL-01-DC-5678. A male and
female were sitting in the front seat. He asked them from where they are coming from. The
lady replied that she is a doctor and is returning home with her husband after attending an
urgent medical case. As instructed by Rahim Sir, I noted down the register number of the
vehicle. I can identify the person travelled in the vehicle on that day.

Krishna Das

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Defence Witnesses

Witness 1: Shanti aged 47 w/o Bhaskaran, Shanti bavan, Ananad, pattom

I am serving as a house-maid in the house of the accused in the last 10 years. The accused
are very kind and affectionate towards me they have no children. Apart from me Mini also
serving as house maid in this house. Both of as residing in the house along with the accused.
On (date 15/6/2020) I served dinner to the accused around 10:30pm there after they went
for sleep at about 1:30am the second accused contacted me through intercom and asked
some water. I bought a jug of water and knocked at the door. The second accused opened
the door with a night dress and I handover the jug. I saw that the second accused was
sleeping in the bed/back. Mini was also staying in another room on that day.

Shanti

Witness 2: Manmohan, Proprietor of Lucky Auto Garage, Pattom,

Thiruvananthapuram

I am the proprietor LUCKY AUTO GARAGE workshop at pattom. First accused is my

close friend, and because of our friendship first accused entrusted the car for periodical
maintenance at my small workshop. Apart from me three persons are working in the
workshop, Renji, Tharun, Sachin. On 13/6/2020 at about 2pm, first accused entrusted the
car to me for periodical maintenance and to repaint some scratches I did the work on and
returned the vehicle on 17/6/2020, 4pm and an amount of Rs.3750/- received as payment
for the repair and alignment works. Since, my workshop is a small institution, and the
customers are very familiar to the us. We are not using Gate pass system and no security is
appointed.

Manmohan

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 Evidence List
DOCUMENT A

13
DOCUMENT B

14
DOCUMENT C

15
DOCUMENT D

16
DOCUMENT E

17
DOCUMENT F

18
DOCUMENT G

19
DOCUMENT H

20
DOCUMENT I

21
DOCUMENT J

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 Postmortem Certificate
P.M. No. 2791/2020 15/06/2020

Body was that of a moderately built and nourished adult male of height
174 cm and a weight of 80 kg. Eyes closed. Conjunctivae Congested. Cornea
Clear. Pupils Dilated. Exteral body orifices were normal. Finger Nail bluish.
Bleaching of fingertips present.

Rigor mortis was fully established and retained all over the body. There
was no sign of decomposition. (Body was kept in a cold chamber)

Injuries (ante mortem)

Contusion 8x6x1 cm on the back of the head across midline, underlying the
occiput.
There was subdural contusion 5x4x0.5 cm on the occipital lobe and
subarachnoid hemorrhage on both sides. Flattening of gyri and narrowing and
narrowing of sulci present.
Air passages were congested and contained mucus. Lungs congested. Heart
showed patent coronary arteries. Stomach contained a handful of soft rice and
other unidentifiable food particles having no unusual smell. Mucosa congested
at places. Urinary bladder empty. All other internal organs were congested,
otherwise appeared normal.

Opinion as to cause of the death

Death was due to injury sustained to the back of the head.

Forwarded to Court

Copy to
SHO, Medical College Police Station

Professor and Head and

Police Surgeon

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DOCUMENT K

ACCUSED 1

24
DOCUMENT L

ACCUSED 2

The identity of the accused is not to be disputed as the accused produced for
sessions during the competition will be different from the above for
convenience of the competition.

25
DOCUMENT M

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