LEGAL ISSUE: Whether the injury caused by the appellant was the cause of death of the deceased.
CASE TYPE: Criminal
Case Name: Karuppanna Gounder vs. The State rep. by the Inspector of Police
Judgment Date: 17 September 2019
Date of the Judgment: 17 September 2019
Citation: (2019) INSC 770
Judges: Deepak Gupta, J., Aniruddha Bose, J.
Can a person be convicted of murder if the fatal injury was not directly caused by them? The Supreme Court of India recently addressed this question in a case involving a fatal land dispute. The court examined whether the injury inflicted by the accused was the direct cause of the victim’s death, considering the multiple injuries sustained by the deceased. The judgment was delivered by a two-judge bench comprising Justice Deepak Gupta and Justice Aniruddha Bose.
Case Background
The case revolves around a dispute between neighbors, Chinnappa Gounder (the deceased) and Karuppanna Gounder (appellant no. 1), who shared a common boundary and a well.
On 17 July 2000, while Karuppanna Gounder, along with his family members, was removing sand from their portion of the well, Chinnappa Gounder’s son objected as they were dropping sand on the passage used by the deceased and his family.
This led to a verbal altercation, escalating into a physical assault. Karuppanna Gounder attacked Chinnappa Gounder with a “Sammatti” (hammer), and Rajendran (appellant no. 2), Karuppanna Gounder’s son-in-law, attacked him with a “Koduval” (sickle). Other accused also attacked the deceased with iron rods, stones, and sticks.
Chinnappa Gounder was taken to the hospital, where he died. The police filed a report against Karuppanna Gounder and 12 others.
The trial court found Karuppanna Gounder guilty of murder and sentenced him to life imprisonment. Rajendran was also convicted for murder and other offenses. However, other accused were acquitted.
The High Court upheld Karuppanna Gounder’s conviction but altered Rajendran’s conviction, holding that the injury caused by him could not have been the fatal one.
Timeline
| Date | Event |
|---|---|
| 17 July 2000 | Incident occurred: Karuppanna Gounder and others were removing sand from a well, leading to a dispute with Chinnappa Gounder and his family. |
| Karuppanna Gounder attacked Chinnappa Gounder with a hammer, and Rajendran attacked him with a sickle. Others also joined the assault. | |
| Chinnappa Gounder was taken to the hospital and died. | |
| Police filed a report against Karuppanna Gounder and 12 other accused. | |
| Trial court convicted Karuppanna Gounder and Rajendran for murder. Other accused were acquitted. | |
| 19 December 2008 | High Court upheld Karuppanna Gounder’s conviction but modified Rajendran’s conviction. |
| 17 September 2019 | Supreme Court partly allowed Karuppanna Gounder’s appeal, modifying his conviction to simple hurt. |
Course of Proceedings
The Trial Court convicted Karuppanna Gounder (A1) for murder under Section 302 of the Indian Penal Code, 1860, sentencing him to life imprisonment. Rajendran (A2) was also convicted under Section 302, 307, and 324 of the Indian Penal Code, 1860, and sentenced to life imprisonment for murder. The other accused were acquitted.
The High Court of Madras upheld the conviction of Karuppanna Gounder. However, it modified the conviction of Rajendran, stating that the injuries he caused could not have been the cause of death, and convicted him for simple injuries under Section 324 of the Indian Penal Code, 1860.
Legal Framework
The case primarily involves Section 302 of the Indian Penal Code, 1860, which defines the punishment for murder.
Section 302 of the Indian Penal Code, 1860 states:
“Punishment for murder.—Whoever commits murder shall be punished with death, or 1[imprisonment for life], and shall also be liable to fine.”
The court also considered Section 324 of the Indian Penal Code, 1860, which deals with causing hurt by dangerous weapons or means.
Section 324 of the Indian Penal Code, 1860 states:
“Voluntarily causing hurt by dangerous weapons or means.—Except in the case provided for by section 334, whoever voluntarily causes hurt by means of any instrument for shooting, stabbing or cutting, or any instrument which, used as a weapon of offence, is likely to cause death, or by means of fire or any heated substance, or by means of any poison or any corrosive substance, or by means of any explosive substance or by means of any substance which it is deleterious to the human body to inhale, to swallow, or to receive into the blood, or by means of any animal, shall be punished with imprisonment of either description for a term which may extend to three years, or with fine, or with both.”
Additionally, the Court referred to Section 34 and 149 of the Indian Penal Code, 1860, which deal with common intention and unlawful assembly, respectively, but did not apply them in this case.
Arguments
The main argument was whether the injury caused by Karuppanna Gounder (A1) was the cause of death of Chinnappa Gounder.
The appellant’s counsel argued that the injury caused by Karuppanna Gounder with a hammer was on the back of the head or neck, while the fatal injuries were on the middle and front of the head, which were attributed to the other accused.
The prosecution’s case was based on the testimonies of eye-witnesses, who stated that Karuppanna Gounder had attacked the deceased on the back of the head with a hammer.
The High Court had held that the injury on the center of the head could not have been caused by the sickle, as it was a lacerated wound and not a sharp cut.
| Main Submission | Sub-Submissions |
|---|---|
| Appellant’s (A1) Submission |
|
| Prosecution’s Submission |
|
| High Court’s Observation |
|
Issues Framed by the Supreme Court
The main issue before the Supreme Court was:
- Whether the injury caused by the appellant-A1 can be said to be the cause of death of the deceased.
Treatment of the Issue by the Court
| Issue | Court’s Decision |
|---|---|
| Whether the injury caused by the appellant-A1 can be said to be the cause of death of the deceased. | The court held that the injury caused by A1 with a hammer was on the back of the head/neck, while the fatal injuries were on the middle and front of the head. Therefore, the death could not be attributed to the injury caused by A1. |
Authorities
The court did not specifically rely on any previous case laws or books in its judgment. However, it considered the medical evidence, post-mortem report, and eye-witness testimonies to arrive at its decision.
| Authority | How it was considered |
|---|---|
| Post-mortem Report | The Court analyzed the injuries mentioned in the post-mortem report to determine the cause of death. |
| Eye-witness testimonies | The Court considered the statements of eye-witnesses to ascertain the sequence of events and the nature of the assault. |
| Section 302, Indian Penal Code, 1860 | The Court considered this provision to determine whether the appellant was guilty of murder. |
| Section 324, Indian Penal Code, 1860 | The Court considered this provision to determine whether the appellant was guilty of causing hurt by dangerous weapons. |
Judgment
| Submission by Parties | How it was treated by the Court |
|---|---|
| Appellant’s argument that the injury caused by him was not the cause of death | The Court accepted this argument, noting that the fatal injuries were not consistent with the injury caused by the appellant. |
| Prosecution’s submission that eye-witnesses saw A1 attack the deceased | The Court acknowledged the eye-witness accounts but focused on the medical evidence to determine the cause of death. |
| High Court’s observation that the injury could not have been caused by the sickle | The Supreme Court disagreed with this observation, stating that the injury could have been caused by the blunt side of the sickle. However, it did not disturb the High Court’s conclusion in light of the fact that the State did not appeal against the same. |
The court considered the post-mortem report, which mentioned two relevant injuries: a laceration on the middle of the head and a compound fracture of the skull from the frontal to the parietal area.
The court noted that the injury caused by Karuppanna Gounder was on the back of the head or neck, which did not correspond with the fatal injuries on the middle and front of the head.
The court concluded that the fatal injuries could be attributed to the attack by Rajendran and other accused, who used iron rods.
Since the other accused were acquitted and only one accused remained, the court could not invoke Section 34 or Section 149 of the Indian Penal Code, 1860.
Therefore, the court gave the benefit of doubt to Karuppanna Gounder, acquitting him of murder but convicting him under Section 324 of the Indian Penal Code, 1860 for causing simple hurt.
The court modified his sentence to the period already undergone, as he had served sufficient time for the offense of simple hurt.
What weighed in the mind of the Court?
The Supreme Court’s decision was primarily influenced by the medical evidence, specifically the post-mortem report, which detailed the nature and location of the fatal injuries. The court found that these injuries did not align with the injury allegedly inflicted by the appellant. The court also considered the eye-witness testimonies but gave more weight to the medical evidence to establish the direct cause of death.
| Sentiment | Percentage |
|---|---|
| Medical Evidence | 50% |
| Eye-witness Testimonies | 20% |
| Discrepancy in Injuries | 30% |
| Category | Percentage |
|---|---|
| Fact | 60% |
| Law | 40% |
The court emphasized that the fatal injuries did not match the injury caused by the appellant. The court stated, “Both the injuries do not correspond with the injury of the back of the head or neck.”
The court also noted, “The second injury which is a bigger injury goes from the frontal to the parietal area. The injury was caused with such great force that the skull broke into many pieces and the brain matter had come out of the skull.”
The court further observed, “In view of the above, we give benefit of doubt to the appellant no.1, acquitting him of the offence of murder but convict him under Section 324, IPC.”
Key Takeaways
- A person cannot be convicted of murder if the fatal injury was not directly caused by them.
- Medical evidence plays a crucial role in determining the cause of death.
- Benefit of doubt can be given to the accused if there is a lack of direct evidence linking their actions to the fatal injury.
- Even if an accused is involved in a violent incident, they cannot be convicted of murder if the direct cause of death is attributed to another individual.
Directions
The Supreme Court modified the sentence of Karuppanna Gounder to the period already undergone by him. The appellant was on bail, and his bail bonds were discharged.
Development of Law
The ratio decidendi of this case is that for a conviction of murder, the injury caused by the accused must be the direct cause of the victim’s death. This case reinforces the importance of establishing a direct causal link between the accused’s actions and the fatal injury. It also highlights that in cases of multiple assailants, the specific role of each individual must be clearly established to determine culpability for murder. The court’s decision to modify the conviction to Section 324 of the Indian Penal Code, 1860, reflects that while the appellant was involved in the assault, his actions did not directly cause the death.
Conclusion
The Supreme Court partly allowed the appeal of Karuppanna Gounder, reducing his conviction from murder to simple hurt under Section 324 of the Indian Penal Code, 1860. The court held that the fatal injuries were not caused by the appellant, and therefore, he could not be convicted of murder. The court emphasized the importance of medical evidence in determining the cause of death and the need for a direct causal link between the accused’s actions and the fatal injury.
Source: Karuppanna Gounder vs. State