Supreme Court Reduces Sentence in Culpable Homicide Case: Chandrakumar vs. State of Madhya Pradesh (2020)

Introduction

Date of the Judgment: 3rd March 2020

Citation: (2020) INSC 197

Judges: R. Banumathi, J. and A.S. Bopanna, J.

Can a High Court reduce a sentence awarded by the Trial Court in a case of culpable homicide? The Supreme Court addressed this question in a recent judgment, focusing on the circumstances of the case and the accused’s personal situation. This case involves an appeal against the High Court’s decision to reduce the sentence of an accused convicted of culpable homicide not amounting to murder. The Supreme Court further reduced the sentence considering the peculiar facts of the case. The judgment was delivered by a two-judge bench comprising Justice R. Banumathi and Justice A.S. Bopanna, with Justice R. Banumathi authoring the opinion.

Case Background

On September 24, 1994, at approximately 5:30 a.m., a verbal altercation occurred at Kanhaiya Dairy, owned by the appellant, Chandrakumar. The deceased, Munna, was milking a buffalo when Chandrakumar approached him and asked to see the bucket of milk. Upon observing that the quantity of milk was less than expected, Chandrakumar allegedly beat Munna on the head with a bamboo stick, causing him to fall unconscious. Munna was taken to the hospital by Chandrakumar and other servants, where he died on October 20, 1994. Initially, the case was registered under Section 307 of the Indian Penal Code (IPC), which deals with attempt to murder, but it was later altered to Section 302 of the IPC, which deals with murder.

Timeline

Course of Proceedings

The Trial Court, after examining the evidence, concluded that Chandrakumar did not intend to cause Munna’s death. Consequently, the Trial Court convicted Chandrakumar under Section 304 Part II of the Indian Penal Code, which pertains to culpable homicide not amounting to murder, and sentenced him to ten years of rigorous imprisonment. Chandrakumar appealed this decision to the High Court of Madhya Pradesh. The High Court, after reviewing the facts and circumstances of the case, reduced the sentence of imprisonment from ten years to five years.

Legal Framework

The case primarily revolves around the application of the following sections of the Indian Penal Code, 1860:
✓ Section 302, Indian Penal Code: This section defines the punishment for murder.
✓ Section 304, Indian Penal Code: This section deals with culpable homicide not amounting to murder. Specifically, Part II of this section addresses cases where the act is done with the knowledge that it is likely to cause death, but without any intention to cause death or cause such bodily injury as is likely to cause death.

The relevant part of Section 304, Indian Penal Code states:

“Whoever commits culpable homicide not amounting to murder shall be punished with imprisonment for life, or imprisonment of either description for a term which may extend to ten years, and shall also be liable to fine, if the act by which the death is caused is done with the intention of causing death, or of causing such bodily injury as is likely to cause death; or with imprisonment of either description for a term which may extend to ten years, or with fine, or with both, if the act is done with the knowledge that it is likely to cause death, but without any intention to cause death, or to cause such bodily injury as is likely to cause death.”

Arguments

Appellant’s Arguments:

• The appellant’s counsel, Mr. Raju Ramachandran, primarily focused on the quantum of sentence rather than challenging the conviction itself.
• It was submitted that the appellant has two daughters of marriageable age, 19 and 21 years, and that there is no other male member in the family to take care of them.
• The counsel pleaded for leniency, highlighting the appellant’s family circumstances.

Respondent’s Arguments:

• The respondent’s counsel, Mr. Ravi Prakash Mehrotra, represented the State of Madhya Pradesh.
• The arguments of the respondent are not explicitly mentioned in the source document. However, it can be inferred that the State argued for upholding the High Court’s decision to reduce the sentence to five years.

Issues Framed by the Supreme Court

The Supreme Court did not explicitly frame any specific issues for determination. However, the primary issue before the court was:
✓ Whether the High Court was justified in reducing the sentence awarded by the Trial Court in a case of culpable homicide not amounting to murder, and whether the Supreme Court should further reduce the sentence.

Treatment of the Issue by the Court

Authorities

The Supreme Court did not explicitly cite any specific cases or legal provisions other than the sections of the Indian Penal Code in its judgment. The decision was primarily based on the specific facts and circumstances of the case and the submissions made by the appellant’s counsel.

Judgment

The Supreme Court, while not explicitly referring to any specific authorities, based its decision on the peculiar facts of the case and the submissions of the appellant’s counsel. The Court considered the appellant’s family circumstances, particularly the presence of two daughters of marriageable age and the absence of a male family member, as a significant factor in reducing the sentence.

What weighed in the mind of the Court?

The Supreme Court’s decision to reduce the sentence was primarily influenced by the appellant’s personal circumstances, particularly the presence of two daughters of marriageable age and the absence of a male member in the family. The Court also considered that the Trial Court had not found the appellant guilty of murder, but rather of culpable homicide not amounting to murder, indicating a lack of intent to cause death. This shows a leaning towards a compassionate approach, balancing the need for justice with the practical realities of the appellant’s family situation. The court also took into consideration that the appellant did not have any intention to cause death.

The Supreme Court’s reasoning was primarily based on the specific facts of the case and the compassionate need to consider the appellant’s family circumstances. The court noted that the Trial Court had not found the appellant guilty of murder, but rather of culpable homicide not amounting to murder, indicating a lack of intent to cause death. The court also considered that the appellant has two daughters of marriageable age and there was no other male member in the family to take care of them. This shows a leaning towards a compassionate approach, balancing the need for justice with the practical realities of the appellant’s family situation.

The judgment includes the following quotes:

“Considering the peculiar facts and circumstances of the case and also the submissions of learned senior counsel appearing on behalf of the appellant-accused, we reduce the sentence of imprisonment awarded to the appellant from five years to two years.”

“The appeal is partly allowed.”

“Since the above order is passed in the peculiar facts and circumstances of the case, the same may not be quoted as a precedent in any other case.”

Key Takeaways

✓ The Supreme Court reduced the sentence of imprisonment from five years to two years, considering the peculiar facts and circumstances of the case, particularly the appellant’s family situation.

✓ The judgment emphasizes that the court may take into account the personal circumstances of the accused when determining the quantum of sentence.

✓ This judgment is specific to its facts and should not be used as a precedent in other cases.

Directions

The Supreme Court did not give any specific directions other than reducing the sentence from five years to two years. It also clarified that this order should not be quoted as a precedent in any other case.

Development of Law

The ratio decidendi of this case is that in cases of culpable homicide not amounting to murder, the Supreme Court can reduce the sentence based on the specific facts and circumstances of the case, especially the personal circumstances of the accused and the absence of intent to cause death. However, this judgment is not to be treated as a precedent. The court did not lay down any new legal principle but reiterated that the courts may take into account the personal circumstances of the accused when determining the quantum of sentence.

Conclusion

In the case of Chandrakumar @ Kali vs. The State of Madhya Pradesh, the Supreme Court reduced the sentence of the appellant from five years to two years, considering the peculiar facts and circumstances of the case, particularly the appellant’s family situation. The court emphasized that this order should not be quoted as a precedent in other cases. This judgment highlights the court’s willingness to consider personal circumstances when determining the quantum of sentence in cases of culpable homicide not amounting to murder.