Supreme Court Reduces Culpable Homicide Sentence: Anbazhagan vs. State (20 July 2023)

Introduction

Date of the Judgment: 20 July 2023
Citation: 2023 INSC 632
Judges: B.R. Gavai, J. and J.B. Pardiwala, J.

When does a fatal blow during a sudden quarrel constitute murder, and when is it merely culpable homicide? The Supreme Court of India recently addressed this question, differentiating between the intention to cause death and the knowledge that an act could cause death. This case involves an appeal by a convict seeking to reduce his sentence for culpable homicide. The court examined the nuances of intent and knowledge under the Indian Penal Code (IPC), ultimately altering the conviction.

Case Background

The appellant, Anbazhagan, an agriculturist, had a land dispute with his neighbor, Balasubramaniam. On 25th October 2015, Anbazhagan and his father were harvesting their Cassava crop when Balasubramaniam objected to a lorry using the pathway to Anbazhagan’s field. This led to a heated argument. The prosecution contended that during the altercation, Anbazhagan struck Balasubramaniam on the head with a “Hoe,” a gardening tool, causing fatal injuries. Balasubramaniam died later in the hospital.

Timeline:

Course of Proceedings

The Trial Court found Anbazhagan guilty of culpable homicide not amounting to murder under Section 304 Part I of the IPC, sentencing him to 10 years of rigorous imprisonment. Anbazhagan’s father was acquitted. Dissatisfied, Anbazhagan appealed to the High Court of Judicature at Madras, which upheld the Trial Court’s decision. Anbazhagan then appealed to the Supreme Court of India.

Legal Framework

The case revolves around Sections 299 and 300 of the Indian Penal Code (IPC).

• Section 299 of the IPC defines culpable homicide as causing death with:
  • (i) the intention of causing death, or
  • (ii) the intention of causing such bodily injury as is likely to cause death, or
  • (iii) with the knowledge that such act is likely to cause death.
• Section 300 of the IPC defines murder as culpable homicide with:
  • (1) the intention of causing death; or
  • (2) 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
  • (3) 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
  • (4) with the knowledge that the act is so imminently dangerous that it must in all probability cause death or such bodily injury as is likely to cause death, and commits such act without any excuse for incurring the risk of causing death or such injury as is mentioned above.

The key distinction lies between intention and knowledge. Intention implies a deliberate aim to cause a specific result, while knowledge refers to the awareness that a particular action is likely to cause a specific result.

Arguments

Appellant’s Arguments:

• The senior counsel for the appellant argued that the case should fall under Section 304 Part II of the IPC, not Part I. He contended that the appellant only had “knowledge” that his act might cause death but did not have the “intention” to kill Balasubramaniam.
• The appellant’s counsel emphasized that the incident occurred during a sudden quarrel, and the single blow did not indicate a premeditated intention to cause death.

Respondent’s Arguments:

• The counsel for the State argued that the Trial Court and High Court correctly convicted the appellant under Section 304 Part I of the IPC.
• The State contended that the case fell under clause thirdly of Section 300 of the IPC, and exception 4 to Section 300 of the IPC was attracted, justifying the conviction under Section 304 Part I.

Issues Framed by the Supreme Court

The Supreme Court framed the primary issue as:

1. Whether the conviction of the appellant for the offence punishable under Section 304 Part I of the IPC should be altered to Section 304 Part II 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:

Judgment

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

How each authority was viewed by the Court?

• The Court relied on Smt. Mathri v. State of Punjab [AIR 1964 SC 986]* to define the concept of “intent”.
• The Court used Basdev v. State of Pepsu [AIR 1956 SC 488]* to distinguish between motive, intention, and knowledge.
• The Court referred to Reg. v. Monkhouse [(1849) 4 COX CC 55(C)]* to explain how intent can be inferred from actions.
• The Court cited In re Kudumula Mahanandi Reddi [AIR 1960 AP 141]* to differentiate between “knowledge” and “intention”.
• The Court followed Virsa Singh v. State of Punjab [AIR 1958 SC 465]* to determine the ingredients of clause thirdly of Section 300 of the IPC, emphasizing the intention to cause the particular injury.
• The Court referred to State of Andhra Pradesh v. Rayavarapu Punnayya [(1976) 4 SCC 382]* to clarify the distinction between culpable homicide and murder.
• The Court cited Phulia Tudu v. State of Bihar [(2007) 14 SCC 588]* to emphasize the importance of understanding the true scope of terms used in Sections 299 and 300 of the IPC.
• The Court used Rajwant Singh v. State of Kerala [AIR 1966 SC 1874]* to understand the application of clause (3) of Section 300 of the IPC.
• The Court referred to Emperor v. Sardarkhan Jaridkhan [AIR 1916 Bom 191]* to highlight the difficulty in determining intent with a single blow.
• The Court discussed Jagrup Singh v. State of Haryana [(1981) 3 SCC 616]* to explain the application of Exception 4 to Section 300 of the IPC.
• The Court used Jawahar Lal v. State of Punjab [(1983) 4 SCC 159]* to understand the knowledge of likelihood of causing death.
• The Court referred to Camilo Vaz v. State of Goa [(2000) 9 SCC 1 : 2000 SCC (Cri) 1128]* to understand the imputation of knowledge in cases of fatal blows.
• The Court cited Jai Prakash v. State (Delhi Admin.) [(1991) 2 SCC 32]* to understand the intention to cause particular injury.
• The Court referred to Anda v. State of Rajasthan [AIR 1966 SC 148]* to analyze Sections 299 and 300 of the IPC.
• The Court cited Vineet Kumar Chauhan v. State of U.P. [(2007) 14 SCC 660]* to emphasize the distinction between murder and culpable homicide.
• The Court used Tholan v. State of Tamil Nadu [AIR 1984 SC 759]* to understand conviction under Section 304 Part II.
• The Court referred to Chamru, Son of Budhwa v. State of Madhya Pradesh [AIR 1954 SC 652]* to understand conviction under Section 304 Part II.
• The Court cited Willie (William) Slaney v. The State of Madhya Pradesh [AIR 1956 SC 116]* to understand conviction under Section 304 Part II.
• The Court used Kulwant Rai v. State of Punjab [(1981) 4 SCC 245]* to understand conviction under Section 304 Part II.
• The Court referred to Jagtar Singh v. State of Punjab [(1983) 2 SCC 342]* to understand conviction under Section 304 Part II.
• The Court cited Hem Raj v. State (Delhi Admn.) [1990 Supp SCC 291]* to understand conviction under Section 304 Part II.
• The Court referred to Pulicherla Nagaraju v. State of A.P. [(2006) 11 SCC 444]* to understand factors for determining intention.

The Supreme Court analyzed the facts and circumstances of the case, noting that the appellant and the deceased had a sudden quarrel over a pathway. The Court observed that the weapon used was a common agricultural tool, and while the blow caused death, there was no evidence to suggest the appellant intended to cause such a fatal injury. The Court concluded that the appellant could only be attributed with the knowledge that his act was likely to cause death, but not the intention to cause death.

The Court stated, “Looking at the overall evidence on record, we find it difficult to come to the conclusion that when the appellant struck the deceased with the weapon of offence, he intended to cause such bodily injury as was sufficient in the ordinary course of nature to cause death.”

The Court further noted, “The weapon of offence in the present case is a common agriculture tool… However, the moot question is – whether that by itself is sufficient to draw an inference that the appellant intended to cause such bodily injury as was sufficient to cause death. We are of the view that the appellant could only be attributed with the knowledge that it was likely to cause an injury which was likely to cause the death.”

The Court emphasized, “It is in such circumstances that we are inclined to take the view that the case on hand does not fall within clause thirdly of Section 300 of the IPC.”

Therefore, the Supreme Court partly allowed the appeal, altering the conviction from Section 304 Part I to Section 304 Part II of the IPC. The appellant’s sentence was reduced to five years of rigorous imprisonment.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the following factors:

• The absence of premeditation or intention to cause death.
• The sudden nature of the quarrel and the use of a common agricultural tool as a weapon.
• The lack of evidence to suggest that the appellant intended to cause the specific injury that resulted in death.
• The distinction between “intention” and “knowledge” under the IPC.

The Court emphasized that while the appellant’s act caused death, the circumstances indicated that he had the knowledge that his act was likely to cause death, but not the intention to cause death.

Logical Reasoning:

Key Takeaways

• The Supreme Court reiterated the crucial distinction between “intention” and “knowledge” in cases of culpable homicide.
• A single blow, even if fatal, does not automatically imply an intention to cause death.
• The nature of the weapon, circumstances of the incident, and the presence of premeditation are crucial factors in determining the appropriate charge.
• The judgment emphasizes that in the absence of a proven intention to cause death or a specific fatal injury, the offense may fall under Section 304 Part II of the IPC.
• This ruling could impact future cases involving sudden altercations and single-blow fatalities, potentially leading to reduced sentences for defendants who did not have the intention to cause death.

Directions

No specific directions were given by the Supreme Court in this judgment.

Specific Amendments Analysis

Not Applicable

Development of Law

Ratio Decidendi:

The ratio decidendi of this case is that in a sudden quarrel where a single blow with a common agricultural tool causes death, the accused can be convicted under Section 304 Part II of the IPC if there is no evidence of intention to cause death, but only knowledge that the act was likely to cause death. The Court emphasized that the intention to cause death is distinct from the knowledge that an act is likely to cause death.

Change in Law:

This judgment does not introduce a new law but reinforces the established legal principles regarding the distinction between intention and knowledge in culpable homicide cases. It provides a clear application of these principles to a specific factual scenario, highlighting the importance of analyzing the circumstances and evidence to determine the appropriate charge. This case serves as a precedent for future cases with similar facts.

Conclusion

The Supreme Court’s decision in Anbazhagan vs. State underscores the critical distinction between intention and knowledge in culpable homicide cases. By altering the conviction from Section 304 Part I to Part II of the IPC, the Court acknowledged that while Anbazhagan’s actions led to Balasubramaniam’s death, the evidence did not support a finding that he intended to cause death. The judgment provides a nuanced understanding of the legal framework and the factors that courts must consider in similar cases. This case serves as a significant reference for future cases involving fatal blows during sudden quarrels, emphasizing the need to carefully assess the intent and knowledge of the accused. The reduction in sentence reflects the Court’s balanced approach in ensuring justice while upholding the principles of criminal law.