INTRODUCTION
Serial Homicides in India is a strange topic to be researched about. Everybody wants to talk about it but nobody wants to research about to a large scale, for which it’s needed. Most serial killer research is Western-centric, with Indian studies few, small, and context-limited. The existing Indian work documents reporting gaps, investigative unpreparedness, and the need for culturally grounded comparative research to address theory, method, and policing shortfalls. The occurrence of serial killing in India is a persistent issue; yet, the existing body of literature on this subject primarily consists of fictional accounts that draw inspiration from a limited fraction of factual information1. Throughout history, India has had numerous instances of serial killings, ranging from the notorious case of Thug Behram in the eighteenth century, allegedly responsible for over 900 deaths, to more recent incidents such as the case of Yerukali Sreenu, who stands accused of murdering 17 women in Telangana2. Notwithstanding the existence of reports, there is a lack of relevant statistical data pertaining to the incidence of fatalities directly associated with this particular category. The annual book titled ‘Crime in India’3 by the National Crime Records Bureau (NCRB) presents statistical data on murders, but does not explicitly specify the occurrence of serial killings within its wide categorisations.
Behavioural theories, pioneered by figures such as B.F. Skinner and Albert Bandura4, emphasize the role of learned behaviour and environmental reinforcement in shaping criminal conduct. According to these theories, serial offenders may develop violent tendencies through a process of conditioning, wherein aggressive behaviour is reinforced by positive outcomes, such as a sense of power or control. Bandura’s social learning theory further posits that individuals learn behaviour through observation and imitation, suggesting that exposure to violence, whether in the home or through media, can increase the likelihood of criminal behaviour.
In the context of Indian serial offending, the role of psychopathy and sociopathy is particularly significant. Many Indian serial offenders exhibit traits consistent with these personality disorders, such as a lack of remorse, manipulative behaviour, and a history of antisocial conduct. For example, the case of Cyanide Mohan, who lured and murdered multiple women, demonstrates the calculated and emotionless nature of psychopathic behaviour. Similarly, the crimes of Thug Behram, a 19th-century serial killer, reflect the sociopathic tendencies of individuals who exploit societal vulnerabilities for personal gain.5
Cognitive theories explain serial offending through distorted thinking, including dehumanising of victims, rationalisation, lack of empathy and grandiose self-view. In the context of India’s violent and unequal relations, such cognitive distortions, for example, as in Surinder Koli’s Noida murders, combine with environmental deprivations to produce extreme violence.
The influence of personality disorders on an offender’s capacity for empathy, impulse control, and decision-making cannot be overstated. Psychopathic individuals, in particular, are often adept at masking their true nature, making them difficult to identify and apprehend. This poses significant challenges for law enforcement and underscores the importance of integrating psychological assessments into criminal profiling and investigative processes.
CORE STATUTORY FRAMEWORK AND JUDICIAL INTERVENTION
Indian law organizes the unlawful killing act via the culpable homicide (section 299 IPC)6 and murder (section 300 IPC)7 under sections 3028 and 3049, where the punishments are considered ranging from death to life imprisonment and culpable homicide not amounting to murder are punished differently by having knowledge about the act or recklessness in the comprehension of the act. None of these provisions distinguishes between single and serial homicide and several killings are charged as distinct counts of sections 302/304, with “seriality” appearing, if at all, only in the narrative as distinct from some foreign systems which create specific serial murder offences or aggravators. The capital-sentencing doctrine of the Supreme Court under section 302 IPC is therefore the central means of decriminalising serial homicide. In Bachan Singh v. State of Punjab10, the Court upheld the constitutional validity of the death penalty but limited it to ‘rarest of rare’ cases because special reasons were necessary under section 354(3) CrPC11 and life imprisonment should be the rule. In Machhi Singh v. State of Punjab12 elaborated aggravating categories- manner of killing, motive, anti-social nature, magnitude and character of victim and expressly mentioned “serial killing” with cruel and meaningless motive and mass or multiple murder of vulnerable victims as paradigmatic rarest of rare situations. There are later multiple murder cases where victim numbers, result repetition and victim vulnerability are considered aggravating, but there are cases where the courts have commuted death where mitigating factors (age, background, reform potential, procedural flaws) dominate, so it is not an automatic reason why a person may be put to death if it is a serial killer. Later multiple-murder cases, victim numbers, repetition and vulnerability considered aggravating factors as to merit commuted cases, however in court cases where mitigating factors have been found to prevail (age, background, reform potential, procedural flaws), seriality is not an automatic ground for capital punishment. The replacement of IPC, with the Bharatiya Nyaya Sanhita (BNS), 202313 carries a forward substantial graded homicide framework; and the CrPC which is being replaced by Bharatiya Nyaya Suraksha Sanhita (BNSS), in 202314, provides a broad structure of judicial sentencing discretion and Capital Punishments.
Indian courts intimate section 84 IPC15 narrowly, particularly when dealing with a serial killer, requiring strict proof of cognitive incapacity, not taking into account disorders affecting impulse control or moral reasoning. This, combined with the lack of a diminished-responsibility doctrine, leaves a blatant conviction-acquittal choice that sentencing judges try to deal with mentally ill offenders informally through ad hoc mitigation.
JUDICIAL PRECEDENTS: LANDMARK CONVICTIONS AND ACQUITTALS
A. Raman Raghav (Bombay, 1965–1968)16
aman Raghav is generally considered to be independent India’s first definite urban serial killer. Between about 1965-66 and then in 1968 again, he roamed the fringes of Bombay (now Mumbai), targeting the pavement dwellers and hutment dwellers sleeping outdoors, bludgeoning them to death with blunt objects. Police linked to him with the help of his confession, recovery of bloody clothing and weapons, and his guided reconstruction of crime scenes of nineteen attacks with nine deaths in 1965-66 as well as another set in 1968. At trial he claimed madness, as divine command to kill, but a government surgeon certified him as being neither a psychotic nor a mentally retarded and the court branded him as a “psychopath” with a “depraved and brutal mentality”, convicting him under section 302 IPC and imposing the death sentence. Appellate and executive interventions changed his punishment to life imprisonment later partly on medical material which showed chronic mental illness but the courts did not accept a full defence of insanity under section 84 IPC.
Raghav’s case thus set an early for the future in which, seriality was punished as an aggravating factor in generic murder law, and courts were reluctant to excuse serial killers for insanity on the basis of cognitive incapacity unless that was clearly proved.
B. Charles Sobhraj (transnational, Indian convictions mid-1970s & 2000s)17
Charles Sobhraj, the Franco Indian-Vietnamese con man and killer that operated across South and South East Asia in the 1970s is better known than domestically but it is part of the India’s serial killer case law. He was arrested in India in 1976 after drugs poisoning a group of French students in Delhi, and was convicted in several cases of poisoning, robbery and murder under IPC 30218, 32819 and the like, being sentenced to many years imprisonment within the Indian prisons before being released and deported in the late 1990s. From a judicial precedent standpoint, Indian courts treated Sobhraj like any repeat, highly organised offender, but in a way essentially within the same doctrinal framework as any multiple murder accused – there was no special category for transnational seriality, rather it was his notoriety that had been generated more in the media than through any novel legal reasoning in reported judgments.
C. Umesh Reddy (Karnataka, 1990s)20
Umesh Reddy, a former police constable, is one of the worst serial rapists and killers in India. Born in 1969, he worked mainly in Karnataka but also in Maharashtra and Gujarat, targeting housewives between the time of late morning and mid-afternoon when men were usually out. He would gain admittance on the pretext of asking for water or an address, then at knifepoint, force the women to undress before they committed rape, and murder them; he kept undergarments and clothing of women for fetishist trophies and hundreds of such items were recovered from his baggage by police.
He confessed to killing 18 women and won conviction in nine cases, with multiple death sentences given to him in section 302 IPC from the Karnataka trial courts, the Karnataka High Court and Supreme Court upheld multiple ones of those convictions, explicitly stating that his crimes were of the rarest of rare category. In a subsequent stage, however, his death sentence was favored to incarceration fixed at 30 years, considering the changing judicial position against infliction of capital punishment even upon serial sex killers and because of the controversial issues of proportionality and public security; controversial news about his privileged lifestyle in jail has added fuel to the debating fire.
D. Surinder Koli & the Nithari/Noida murders (2005–2006)21
The Nithari (Noida) killings of multiple children and women whose bodies were discovered behind house D5 in 2006, had initially resulted in a rash of convictions and death sentences for domestic worker Surinder (Surendra) Koli and one Moninder Singh Pandher – his employer and a businessman. Trial courts of Ghaziabad convicted Koli in many cases and Pandher in few cases, including death in cases of rape and murder of minors under section 302 IPC and allied sections. In October 2023, Allahabad High Court in 12 appeals22 from Bajpayee to delve into the related 12 cases acquitted Koli and Pandher as holding that the investigation was “botched up” and did not prove guilt beyond reasonable doubt on the circumstantial evidence. The Court laid increased emphasis on misuse or improper use of disclosure statements, doubtful recoveries from open drains and poor corroboration of the evidence by forensically and refused to let media stories of monstrosity replace legal standards. In 2025 the Supreme Court of India rejected 14 appeals23 by the CBI and the victim’s families on the basis of the reasoning of the High Court and describing its appreciation of evidence was free from perversity. In a separate curative petition, it also set aside the one conviction Koli had left surviving, and ordered his release. Nithari is therefore a landmark acquittal, which despite being an archetypal prosecution of serial homicide involving extreme publicity, the higher courts insisted on the highest evidentiary standards of compliance and showed no hesitation to undermine a whole edifice of death sentences when the process of due identification was breached.
E. Cyanide Mohan Kumar (Karnataka, 2005–2009)24
Mohan Kumar, a former primary school physical education teacher from Karnataka, enticed scores of unmarried women into relationships with the lure of marriage and then inspired them to inject “contraceptive pills” which were actually cyanide pills. The women usually died in public toilets or in lodges where they had withdrawn in privacy to ingest the tablets whereupon Mohan stole their jewellery and valuables. The Police were able to link him to a series of similar deaths eventually. He was then, tried in at least multiple cases and convicted of committing murder under section 302 IPC amongst other charges through cases matter, High Court and Supreme Court scrutiny took place in his later appeals for at least one of them to be tried in Kannada court, which sentenced him to death.
His case has often been cited in the legal and criminological literature as the archetypal case of the calculating, greed motivated serial poisoner who exploits romantic and gendered vulnerability, and also cited as an example of the court’s origin of seriality plus deception as an aggravating factor justifying very severe punishment.
F. M. Jaishankar (South India, 2008–2011)25
M. Jaishankar known as ‘Psycho Shankar’ that was active between 2008 and 2011 across Tamil Nadu, Karnataka and Andhra Pradesh, which committed estimated 19+ murders and about 30 rapes and robberies mostly targeting women in lonely places near to highway. He raped and murdered a woman police constable M. Jayamani in 2009, abducted her after she was put on duty and killed her after several assaults, a crime that intensified attempts to arrest him. He was arrested in 2009, escaped from Dharmapuri during a court transfer in Karnataka in 2011 to commit more crimes, then he went to be arrested once more from Karnataka, but he escaped from the Bangalore Parappana Agrahara prison in 2013, soon after he was recaptured by the police under strict solitary confinement. By the year 2013, he was convicted in several rape murder cases and given lengthy terms of imprisonment (in some cases cumulative double digit year terms) and some life sentences in courts in Tamil Nadu and Karnataka. In 2018, he committed suicide in his cell at the Bangalore jail by cutting his own throat. Jaishankar’s case shows how serial offending and reoffending places a heavy burden on the criminal justice machinery; however, doctrinally in this case, the courts did not make any significant deviation by providing a special separate regime for serial offenders but instead pursued a different remedy of stacking the sentences.
CONCLUSION
The study has been conducted to gain deeper understanding of the problem and find the implementation gaps and what compels a human to commit such acts. Because the law does not name or track “serial homicide” as a separation category, the patterns of repeated killing do not get mapped by investigators and courts in any systematic manner, making data collection, macro-analysis and policy design very difficult. Criminal profiling and forensic psychology are just beginning to make an inroad in India but by and large, most investigations of serial murders still rely on conventional tools – informers, confessions, weapon recovery – rather than behavioural linkages or victimology or specialist multi-disciplinary teams. This is being reinforced by resource constraints as well as a doctrinal framework where it is treated the same by sections 302 and 304 and there is not automatically a procedural trigger for the use of advanced techniques when repetition is suspected. Seriality consequentially emerges as a narrative and sentencing aggravator while section 84 IPC is narrowly applied and there is little room for diminished responsibility although in instances of obvious psychological disturbance such as in the cases of female serial offenders such as Cyanide Mallika26 and Jolly Joseph27, embedded in/within the domestic and psychological violence is processed through the rigid channels. The study also perceives the lives of Indian serial killers hermeneutically, finding that serial murder is due to interaction between innate traits and multiple life factors and trigger incidents. It puts stress on the fact that each offender’s story provides unique clues and calls for co-operation between psychologists, criminologists, lawyers and other experts to build a fuller picture.
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Footnotes
1. S.A. Deepak, Serial Killings in India: Case Studies and Profiling Strategies, Criminal Psychology and the Criminal Justice System in India and Beyond, pp 1 – 12, available at https://doi.org/10.1007/978-981-16-4570-9_8
2. M. Dash, Thug: The true story of India’s murderous cult. Pp. 256-58, Granta Books, (2005).
3. National Crime Records Bureau, Ministry of Home Affairs, Government of India, Vol. I, Crime in India, New Delhi, December 2023
4. John B. Watson (1878–1958), State University, available at, https://education.stateuniversity.com/pages/2543/ Watson-John-B-1878-1958
5. Shreya Modi & Krupa Nishar, Unlocking the Enigma of Indian Serial Killers: An Insight into their Biopsychosocial Construction, 5 IJFMR 1, 5 (Sept.-Oct. 2023), available at https://ijfmr.com/papers/2023/5/7769.pdf.
6. Indian Penal Code, Act No. 45 of 1860, s.299
7. Indian Penal Code, Act No. 45 of 1860, s.300
8. Indian Penal Code, Act No. 45 of 1860, s.302
9. Indian Penal Code, Act No. 45 of 1860, s.304
10. AIR 1980 SC 898
11. Act No. 2 of 1974
12. 1983 AIR 957
13. No. 45 of 2023
14. No. 46 of 2023
15. Act No. 45 of 1860, s.84
16. State Of Maharashtra vs Sindhi Alias Raman (1987) 89 BOMLR 423
17. Charles Sobraj vs The Suptd., Central Jail, Tihar, AIR 1978 SUPREME COURT 1514,
18. Act No. 45 of 1860, s.302
19. Act No. 45 of 1860, s.328
20. State of Karnataka v. B.A. Umesh (2011) 2 SCC 496, and Criminal Appeal No. 250 of 2009
21. Surendra Koli v. State of U.P., (2011) 4 SCC 807
22. 2023: AHC:199091-DB
23. 2025 INSC 1308
24. The Registrar General v. Mohan Kumar @ Sudhakar @ Shashidhar Poojary, CRL.RC 4/2014 (Oct 24, 2017)
25. Editorial, “Serial rape convict ‘Psycho Jaishankar’ slits own throat, kills self in Bengaluru Central Prison” The New Indian Express, Feb 28, 2018
26. Mallika @ Kala @ Kempamma vs State of Karnataka, AIR ONLINE 2018 KAR 2344
27. Jollyamma Joseph v. State of Kerala, Bail Appl. No. 4628 of 2020