PATHMANABHAN A/L NALLIANNEN & ORS v PP [2013] 5 MLJ 867
Without a body, many assume there is no murder. No corpse, no certainty. And when the final physical proof is missing, people think the case must collapse. The reality is this: truth does not always come in the form of a body — it is built from traces, patterns, and evidence that reinforce one another.
There was a case where four individuals left for a rural area — and never returned. Days passed. Weeks passed. Families began searching. Police reports were lodged. Yet no bodies were found. No graves. No eyewitnesses to the killings. All that remained was silence — and many unanswered questions.
The investigation later revealed a far darker picture. Police discovered bloodstains at several locations. The victims’ DNA profiles were found in different places. Telecommunications records showed suspicious movements and communications. Personal belongings of the victims were recovered — but not with their owners.
More troubling still, the investigation uncovered that one of the accused had a financial interest in land owned by one of the victims. A motive began to emerge — not mere suspicion, but a concrete financial incentive.
When the case went to trial, the defence narratives became increasingly inconsistent. The accused contradicted one another. Fingers were pointed. Some attempted to distance themselves. Others changed their versions of events. The court found these inconsistencies were not minor — they went to the very core of what happened and who was involved.
The court affirmed a crucial principle: A murder conviction does not necessarily require the discovery of a body. What must be proven is the totality of the facts — whether the evidence, when viewed as a whole, leads to one unavoidable conclusion: that the victims were killed, and that the killings were carried out by the accused.
In this case, although no bodies were recovered, the circumstantial evidence was too strong to ignore. Bloodstains. DNA. Call records. Financial motive. The conduct of the accused before and after the incident. And testimony from the victims’ families showing that the victims did not disappear voluntarily.
The court also referred to principles from earlier cases overseas, which confirmed that the absence of a body is not a barrier to conviction, provided the remaining facts form a complete and consistent chain of evidence.
The court described the case as a brutal plan executed with extreme cruelty — not a spontaneous crime, but an act that was planned, carried out, and deliberately concealed.
Ultimately, the court convicted the accused based on strong circumstantial evidence that mutually supported one another.Lesson learned:
In criminal law, truth does not depend on a single piece of evidence. A body may be missing. Eyewitnesses may be absent. But when circumstantial evidence forms a complete, reasonable, and coherent story — justice can still be done.
