A Palakkad court sentenced a man named Chenthamara to death this week for hacking two people to death at their home in Pothundy. The judgment leaned entirely on a single legal standard, the rarest of rare doctrine, the test Indian courts have used for decades to decide when a murder conviction should end in a death sentence instead of life imprisonment. Here’s what the case involved, and why the court decided it met the rarest of rare threshold.
What Happened in the Pothundy Double Murder Case
According to the prosecution, Chenthamara killed Sudhakaran, 50, and Sudhakaran’s 75-year-old mother, Lakshmi, at their home in Boyan Colony, Pothundy, on January 27, 2025. Both victims were hacked to death. The Additional District and Sessions Court-IV in Palakkad, presided over by Judge Kenneth George, convicted him under Sections 103(1) and 126(2) of the Bharatiya Nyaya Sanhita, with Section 103(1) being the provision that punishes murder with death or life imprisonment.
This wasn’t Chenthamara’s first conviction connected to the same family. In October 2025, the same court had already sentenced him to double life imprisonment for murdering Sajita, Sudhakaran’s wife. According to the prosecution, Chenthamara blamed Sudhakaran’s family for his wife and daughter leaving him, and later came to believe they had used black magic against him. He was out on bail in the Sajita murder case when he returned to Pothundy, in violation of his bail conditions, and killed Sudhakaran and Lakshmi.
The Rarest of Rare Doctrine, Explained
Murder under Indian law carries two possible sentences, death or life imprisonment, and the default has always leaned toward the latter. In Bachan Singh v. State of Punjab (1980), the Supreme Court held that life imprisonment is the rule and death is the exception, reserved only for cases so extreme that no other punishment would be adequate, cases that would later come to be described as rarest of rare.
Macchi Singh v. State of Punjab (1983) tried to make this standard more workable by laying out categories where a case might genuinely count as rarest of rare, extreme brutality, the manner of the killing, the motive behind it, and whether the crime shocks the collective conscience of society. Even so, courts have acknowledged over the years, including in Shankar Kisanrao Khade v. State of Maharashtra (2013), that the line between an ordinary murder and a rarest of rare one is often unclear and depends heavily on the facts of each case.
Why the Court Found This Case Fit the Standard
The Palakkad court didn’t rely on the brutality of the killings alone to reach a rarest of rare finding. Judge Kenneth George specifically pointed to Chenthamara’s lack of remorse, his repeated attempts to justify the murders, and his continued threats against the victims’ family as reasons the case crossed into rarest of rare territory. The judge also accepted the prosecution’s argument that the killings were premeditated, not a sudden act of violence.
What likely mattered most was the pattern behind it. This was Chenthamara’s second conviction for killing a member of the same family, and he had committed this second set of murders while out on bail for the first. The court held that this made him a continuing threat to society, one of the specific factors courts weigh in the rarest of rare cases even after accounting for any circumstances in the accused’s favour. Notably, the court also held that the case being built on circumstantial evidence did not, by itself, rule out a death sentence.
The Compensation Order and What Comes Next
Alongside the death sentence, the court imposed a fine of ₹20 lakh, to be paid as compensation to the victims’ children. Since Chenthamara has no means to pay this himself, the court directed the State to bear the compensation instead.
The death sentence isn’t final yet. Under Indian law, every death sentence passed by a trial court needs confirmation by the High Court before it can be carried out, and that process is now what lies ahead for this case at the Kerala High Court. This confirmation stage works differently from an ordinary criminal appeal, since the High Court examines the entire record on its own even without a formal appeal being filed. For more on how appeals and reviews work in criminal cases generally, see CrPC: Appeal Vs. Review. Given how narrowly courts are expected to apply the rarest of rare standard, that confirmation stage is where the reasoning behind this sentence will be tested again.
Conclusion
This case shows how much weight courts place on pattern and conduct, not just the act of killing itself, when deciding whether something counts as rarest of rare. Two murders of the same family, a bail violation, and a complete absence of remorse were treated together as proof that lesser punishment wouldn’t be enough. Whether the Kerala High Court agrees with that reasoning is the next question this case will have to answer.
Written by: Khushi Mittal
