Supreme Court Converts Murder Conviction to Culpable Homicide in Love Triangle Case

Date of the Judgment: 6th September 2023

Citation: 2023 INSC 812

Judges: S. Ravindra Bhat, J., Aravind Kumar, J.

Can a sudden act of violence during a heated argument be considered murder? The Supreme Court of India recently examined this question in a case involving a love triangle, where the accused, in a fit of rage, caused the death of his former girlfriend. This judgment clarifies the legal difference between murder and culpable homicide, particularly when the intention to kill is not clearly established. The bench, comprising Justices S. Ravindra Bhat and Aravind Kumar, delivered the judgment, with Justice Aravind Kumar authoring the opinion.

Case Background

The case revolves around the death of Sangeetha, who was in a relationship with the appellant, N. Ramkumar. According to the prosecution, Sangeetha became unhappy with Ramkumar’s behavior, and her mother had warned them about it. Sangeetha eventually ended the relationship and started talking to her neighbor, Mr. Sudhakar. This angered Ramkumar. On June 19, 2010, at approximately 10:30 p.m., Ramkumar allegedly trespassed into Sangeetha’s house and confronted her about her relationship with Sudhakar. In a fit of rage, he is said to have grabbed her by the ears and hit her head against the wall, after which he fled the scene. Sangeetha was admitted to the hospital by her mother (PW-1) and neighbor (PW-2). Three days later, a complaint was lodged, leading to the registration of FIR No. 1659 of 2010. Initially, the charges were under Sections 294(b), 448, 323, and 506(1) of the Indian Penal Code (IPC), and Section 4 of the Tamil Nadu Prohibition of Harassment of Women Act. On June 28, 2010, Sangeetha’s condition worsened, and she died on June 29, 2010, at 3:30 a.m. Following her death, the charges were altered to include Section 302 of the IPC (murder).

Timeline:

Course of Proceedings

The First Additional District Judge (NCR), Tiruchirappalli, convicted Ramkumar under Sections 450 (house-trespass) and 302 (murder) of the IPC. He was sentenced to five years of rigorous imprisonment and a fine of Rs. 50,000 for the offense under Section 450, and life imprisonment with a fine of Rs. 60,000 for the offense under Section 302. The sentences were to run concurrently. Ramkumar then appealed to the Madurai bench of the Madras High Court, which upheld the trial court’s decision, concluding that Ramkumar had intentionally caused the injury that led to Sangeetha’s death. The High Court stated that Ramkumar’s actions fell under the first limb of Section 300 of the IPC, thus making him liable for murder under Section 302 of the IPC.

Legal Framework

The case primarily revolves around the interpretation of Sections 300, 302, and 304 of the Indian Penal Code, 1860.

Section 300 of the IPC defines murder. It states, in part, that culpable homicide is murder if the act by which the death is caused is done with the intention of causing death, or if it is done with the intention of causing such bodily injury as the offender knows to be likely to cause the death of the person to whom the harm is caused, or if it is done with the intention of causing bodily injury to any person and the bodily injury intended to be inflicted is sufficient in the ordinary course of nature to cause death, or if the person committing the act knows that it is so imminently dangerous that it must, in all probability, cause death or such bodily injury as is likely to cause death.

Section 302 of the IPC prescribes the punishment for murder, which is imprisonment for life or death.

Section 304 of the IPC deals with culpable homicide not amounting to murder. It is divided into two parts: Part I deals with cases where the act is done with the intention of causing death or such bodily injury as is likely to cause death, and Part II deals with cases where the act is done with the knowledge that it is likely to cause death, but without any intention to cause death or such bodily injury as is likely to cause death.

The Supreme Court also considered the distinction between “intention” and “knowledge” as used in the IPC, noting that while they are related, they are not the same. Intention refers to the purpose or design with which an act is done, while knowledge refers to an awareness of the consequences of the act. The Court emphasized that the legislature has used these two terms distinctly, providing separate punishments for acts done with intent and those done with knowledge. The Court also referred to the principle that “culpable homicide” is a genus, and “murder” is its species, meaning all murders are culpable homicides, but not all culpable homicides are murders.

Arguments

Appellant’s Arguments:

• The appellant’s counsel, Shri M. A. Chinnasamy, argued that there was a delay in filing the complaint, which casts doubt on the prosecution’s theory.
• He contended that the conviction was based solely on the testimony of PW-1 (the deceased’s mother), whose statements were contradictory and unreliable. He also pointed out that PW-1 was against her daughter’s relationship with the accused, suggesting bias.
• The counsel highlighted inconsistencies in the prosecution’s case, such as the claim of blood on the kitchen floor, which was not corroborated by the investigating officer (PW-12) or PW-5.
• He also noted that the initial complaint stated that the accused punched the deceased on the face, whereas PW-1 later testified that the accused held her ears and dashed her against the wall.
• The non-examination of the auto-rickshaw driver who allegedly transported the deceased to the hospital was also raised as a point of doubt.
• It was further argued that the clothes of neither the accused nor the victim were sent for chemical analysis.
• The counsel argued that even if the court were to affirm the findings of the lower courts, the sentence should be converted to one under the second part of Section 304 of the IPC, as the accused did not have the intention to cause death, but his act was likely to cause death.

Respondent’s Arguments:

• The respondent’s counsel argued that the evidence presented by the prosecution was not successfully challenged and that the prosecution witnesses stood firm during cross-examination.
• They contended that the accused, unable to accept Sangeetha’s relationship with Sudhakar, took the extreme step of killing her.
• The respondent supported the High Court’s conclusion that the accused had gone to Sangeetha’s house with the intention to eliminate her, which falls under the first limb of Section 300 of the IPC.

[TABLE] of Submissions:

Innovativeness of the argument: The appellant’s argument to convert the sentence to Section 304 Part II of the IPC, based on the lack of intention to cause death, is a key innovative aspect of the defense.

Issues Framed by the Supreme Court

The Supreme Court framed the following issue for consideration:

1. Whether the judgment, order, and sentence passed by the Sessions Court and affirmed by the High Court require to be affirmed, or whether the sentence is to be converted and punishment to be awarded under Section 304 of the IPC, and if so, which part of Section 304 of the IPC?

Treatment of the Issue by the Court

The following table demonstrates as to how the Court decided the issues

Authorities

The Supreme Court considered the following authorities:

Cases:

• Rampal Singh Vs. State of Uttar Pradesh (2012) 8 SCC 289 – The court referred to this case to highlight the principle that “culpable homicide” is a genus and “murder” is its species, and that all murders are culpable homicides, but not all culpable homicides are murders.
• Basdev Vs. State of Pepsu AIR 1956 SC 488 – This case was cited to distinguish between motive, intention, and knowledge. The court observed that intention and knowledge can sometimes merge, but they are not the same thing and that knowledge is an awareness of the consequences of the act.
• Pulicherla Nagaraju @ Nagaraja Reddy vs State of Andhra Pradesh, AIR 2006 SC 3010 – This case was used to explain the factors that should be considered when determining whether an act constitutes murder or culpable homicide not amounting to murder. It was emphasized that the intention to cause death can be gathered from a combination of circumstances, such as the nature of the weapon used, the part of the body injured, and the amount of force employed.
• Pratap Singh @ Pikki v. State of Uttarakhand (2019) 7 SCC 424 – This case was cited to show that when an incident occurs in the heat of the moment, without premeditation, the offense can be converted to Section 304 Part II of the IPC.
• Deepak v. State of Uttar Pradesh (2018) 8 SCC 228 – This case was used to illustrate that a single blow in the heat of the moment, without premeditation, can lead to a conviction under Section 304 Part II of the IPC rather than Section 302 of the IPC.
• Anbazhagan vs. The State represented by the Inspector of Police in Criminal Appeal No.2043 of 2023 – This recent judgment was used to define the true test to be adopted to find out the intention or knowledge of the accused in doing the act. It was also used to explain the difference between the two parts of Section 304 of the IPC, noting that the first part applies when there is “guilty intention,” while the second part applies when there is no such intention but there is “guilty knowledge.”

Legal Provisions:

• Section 300 of the Indian Penal Code, 1860 – The court examined this section to determine whether the act of the accused constituted murder. The court specifically considered the clauses related to the intention to cause death or bodily injury sufficient to cause death.
• Section 302 of the Indian Penal Code, 1860 – This section specifies the punishment for murder. The court considered whether the initial conviction under this section was appropriate.
• Section 304 of the Indian Penal Code, 1860 – The court examined this section to determine whether the act of the accused constituted culpable homicide not amounting to murder. The court specifically considered Part II of this section, which applies when the act is done with the knowledge that it is likely to cause death but without the intention to cause death or such bodily injury as is likely to cause death.

[TABLE] of Authorities:

Judgment

How each submission made by the Parties was treated by the Court?

How each authority was viewed by the Court?

✓ Rampal Singh Vs. State of Uttar Pradesh [(2012) 8 SCC 289]* was used to establish the basic principle that all murders are culpable homicides, but not all culpable homicides are murders, setting the stage for the distinction the court needed to make.

✓ Basdev Vs. State of Pepsu [AIR 1956 SC 488]* was used to clarify the difference between motive, intention, and knowledge, which is crucial for determining the appropriate charge.

✓ Pulicherla Nagaraju @ Nagaraja Reddy vs State of Andhra Pradesh [AIR 2006 SC 3010]* was used to outline the factors to be considered when determining intention, such as the nature of the weapon, the part of the body injured, and the amount of force used.

✓ Pratap Singh @ Pikki v. State of Uttarakhand [(2019) 7 SCC 424]* was used to support the conversion of the sentence from Section 302 to Section 304 Part II in cases where the incident occurred in the heat of the moment.

✓ Deepak v. State of Uttar Pradesh [(2018) 8 SCC 228]* was used as a precedent for converting the offense from murder to culpable homicide not amounting to murder when a single blow was inflicted without premeditation.

✓ Anbazhagan vs. The State represented by the Inspector of Police in Criminal Appeal No.2043 of 2023* was used to define the test for intention and knowledge and to explain the difference between the two parts of Section 304 of the IPC, further clarifying the court’s reasoning for converting the conviction.

What weighed in the mind of the Court?

The Supreme Court’s decision to convert the conviction from murder under Section 302 of the IPC to culpable homicide not amounting to murder under Section 304 Part II of the IPC was based on a careful analysis of the facts and circumstances of the case, as well as the relevant legal principles. The court emphasized that the accused did not have the intention to cause death, but his act was done with the knowledge that it was likely to cause death. The court found that the incident occurred in the heat of the moment, without premeditation, and that the accused’s actions were the result of a sudden quarrel and emotional outburst. The court also considered the fact that the accused and the deceased were in a relationship, and the incident occurred due to a dispute regarding the deceased’s relationship with another person.

Sentiment Analysis of Reasons Given by the Supreme Court:

Fact:Law Ratio:

Logical Reasoning:

The court considered alternative interpretations, such as the possibility that the accused had intended to kill the deceased. However, the court rejected this interpretation based on the facts of the case, including the lack of premeditation, the single assault, and the short duration of the incident. The court also considered the fact that the accused and the deceased were in a relationship, which suggested that the incident was not a planned act of violence. The court ultimately concluded that the accused’s act fell under Section 304 Part II of the IPC, which applies when the act is done with the knowledge that it is likely to cause death but without the intention to cause death or such bodily injury as is likely to cause death. The court’s decision was based on a careful analysis of the facts, the law, and the relevant legal precedents. The majority opinion was authored by Justice Aravind Kumar.

Key Takeaways

• The judgment clarifies the distinction between murder and culpable homicide not amounting to murder, emphasizing that the intention of the accused is a key factor in determining the nature of the offense.
• It highlights that acts done in the heat of the moment, without premeditation, and with knowledge that they are likely to cause death, may fall under Section 304 Part II of the IPC rather than Section 302 of the IPC.
• The judgment provides guidance on the factors to be considered when determining intention, such as the nature of the weapon used, the part of the body injured, and the amount of force employed.
• It underscores the importance of considering the specific facts and circumstances of each case when determining the appropriate charge.
• The judgment may have implications for future cases involving similar circumstances, particularly those involving sudden altercations and emotional outbursts.

Directions

The Supreme Court directed that the appellant’s conviction under Section 302 of the IPC be altered to one under Section 304 Part II of the IPC. The court further directed that the appellant be sentenced to the period of imprisonment already undergone and be released forthwith if not required in any other case.

Specific Amendments Analysis

There were no specific amendments discussed in the judgment.

Development of Law

The ratio decidendi of this case is that in cases where the act causing death is not premeditated, occurs in the heat of the moment, and is done with the knowledge that it is likely to cause death but without the intention to cause death or such bodily injury as is likely to cause death, the offense is culpable homicide not amounting to murder under Section 304 Part II of the IPC rather than murder under Section 302 of the IPC. This judgment reinforces the distinction between murder and culpable homicide not amounting to murder, and it provides guidance on the factors to be considered when making this distinction. This judgment does not change any previous position of law but rather reinforces the existing principles and provides a clear application of these principles to a specific set of facts.

Conclusion

The Supreme Court’s judgment in the case of N. Ramkumar vs. The State Rep. by Inspector of Police is a significant one as it reinforces the importance of distinguishing between murder and culpable homicide not amounting to murder. The court converted the murder conviction to culpable homicide, emphasizing that the absence of premeditation and the act being committed in the heat of the moment are crucial factors. This decision highlights the need to carefully analyze the intention and knowledge of the accused in such cases, ensuring that the punishment is proportionate to the crime. The judgment serves as a reminder that not all acts resulting in death constitute murder and that the legal system must consider the specific circumstances of each case to arrive at a just and fair outcome. The Supreme Court partly allowed the appeal, converting the conviction under Section 302 IPC to Section 304 Part II IPC, and sentenced the appellant to the period already undergone.