Supreme Court Reinstates Murder Conviction, Overturning High Court in Uttar Pradesh Case (2022)

Date of the Judgment: 19 January 2022

Citation: 2022 INSC 71

Judges: M.R. Shah, J. and B.V. Nagarathna, J.

Can a conviction for murder be overturned simply because the victim died a few days after the assault and didn’t sustain a skull fracture? The Supreme Court of India recently addressed this crucial question in a criminal appeal from Uttar Pradesh. The court examined whether the High Court was correct in reducing the conviction from murder to grievous hurt. This case highlights the importance of considering all medical evidence when determining the nature of an offense. The judgment was delivered by a two-judge bench comprising Justice M.R. Shah and Justice B.V. Nagarathna.

Case Background

On the evening of 20th December 1983, the deceased, Ram Autar, was working in his agricultural field when the accused, Jai Dutt, Lal Bahadur, Sher Singh, and Shastri, arrived. They began abusing him and subsequently assaulted him with various weapons. Ram Autar sustained multiple injuries and was taken to a hospital in Lucknow. He died six days later due to his injuries. The prosecution argued that the accused intended to cause grievous harm, leading to Ram Autar’s death. The accused were charged under Section 302 of the Indian Penal Code (IPC) for murder, with the exception of Jai Dutt, who was charged under Section 302 read with Section 34 of the IPC.

Timeline

Course of Proceedings

The Trial Court convicted Jai Dutt under Section 302 of the Indian Penal Code (IPC) and sentenced him to life imprisonment. The other accused, Lal Bahadur, Sher Singh, and Shastri, were convicted under Section 302 read with Section 34 of the IPC and also sentenced to life imprisonment. The accused appealed to the High Court of Judicature at Allahabad. During the appeal, Lal Bahadur and Sher Singh passed away, causing the appeal to abate for them. The High Court partly allowed the appeal for Jai Dutt and Shastri, converting their conviction from Section 302 read with Section 34 of the IPC to Section 326 of the IPC. The High Court reasoned that the death occurred six days after the incident and no skull fracture was found. The State of Uttar Pradesh then appealed to the Supreme Court.

Legal Framework

The case primarily revolves around the interpretation of the following sections of the Indian Penal Code, 1860:

• Section 302, Indian Penal Code, 1860: This section defines the punishment for murder. It states, “Whoever commits murder shall be punished with death, or imprisonment for life, and shall also be liable to fine.”
• Section 34, Indian Penal Code, 1860: This section deals with acts done by several persons in furtherance of common intention. It states, “When a criminal act is done by several persons in furtherance of the common intention of all, each of such persons is liable for that act in the same manner as if it were done by him alone.”
• Section 326, Indian Penal Code, 1860: This section addresses voluntarily causing grievous hurt by dangerous weapons or means. It states, “Whoever, except in the case provided for by section 335, voluntarily causes grievous 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 for life, or with imprisonment of either description for a term which may extend to ten years, and shall also be liable to fine.”

Arguments

Appellant (State of Uttar Pradesh):

• The High Court erred in converting the conviction from Section 302 to Section 326 of the IPC.
• The High Court had accepted that the accused went to the deceased’s field, initiated the quarrel, and used weapons to cause injuries.
• The eye-witnesses (PW1 and PW2) were deemed trustworthy by the High Court, and their statements should not have been disbelieved.
• The deceased died due to head injuries, which constitutes murder. The High Court should not have reduced the conviction.
• The fact that the deceased died six days after the incident should not be a ground to convert the conviction.
• The High Court failed to consider the injuries mentioned in the post-mortem report and the cause of death.
• The absence of a skull fracture should not negate the conviction under Section 302 of the IPC, as death can result from internal injuries.

Respondent (Accused):

• The High Court was correct in acquitting the accused under Section 302 of the IPC and converting the conviction to Section 326 of the IPC.
• The deceased had no fracture on his head and died six days after the incident.
• The injuries were not serious or grave.
• The injuries observed by Dr. B.L. Katiyar at the PHC were simple in nature.
• The incident occurred on the spur of the moment due to a minor dispute, and there was no intention to kill the deceased.

Issues Framed by the Supreme Court

The Supreme Court considered the following issue:

1. Whether the High Court was justified in converting the conviction under Section 302 of the Indian Penal Code (IPC) to Section 326 of the IPC, based on the fact that the deceased died six days after the incident and there was no fracture on the head?

Treatment of the Issue by the Court

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

Authorities

The Supreme Court did not explicitly cite any previous cases or books in this judgment. The court primarily relied on the factual evidence presented, including the post-mortem report and the testimonies of the witnesses.

Judgment

How each authority was viewed by the Court?

✓ The post-mortem report was crucial in establishing that the cause of death was head injury and that it was fatal. The court relied on the medical evidence to conclude that the offense fell under Section 302 of the IPC.

✓ The Court upheld the testimonies of PW1 and PW2, as the High Court had already deemed them trustworthy. This helped establish the sequence of events leading to the assault.

✓ The testimony of Dr. P.R. Mishra (PW8) was vital in confirming the cause of death as subdural hematoma over both temporal lobes due to head injury, thus establishing the gravity of the assault.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the medical evidence, particularly the post-mortem report and the testimony of the doctor who conducted it. The Court emphasized that the High Court had overlooked critical aspects of this evidence, leading to an incorrect conversion of the conviction. The fact that the deceased died due to a head injury, regardless of the absence of a skull fracture, was paramount in the Supreme Court’s reasoning. The Court also considered the fact that the accused had gone to the deceased’s field with weapons and initiated the assault, indicating a clear intention to cause harm.

Logical Reasoning:

The court considered the argument that the deceased died after six days and that there was no skull fracture. However, it rejected this argument, emphasizing that the cause of death was the head injury, which was a vital part of the body. The court noted that the High Court’s reasoning was flawed because it did not consider the internal injuries and the medical evidence that clearly indicated a fatal head injury. The Supreme Court concluded that the High Court’s conversion of the conviction was unsustainable and restored the trial court’s judgment.

The Supreme Court quoted from the post-mortem report, stating, “1. Scabbed abraded contusion 8 cm x 6 cm on the left side of head above the left eye brow… As per the doctor the deceased died due to head injury no.1.”

The Supreme Court also highlighted the medical evidence, noting, “As per the deposition of Dr. P.R. Mishra – PW8 who conducted the post mortem, on opening of the brain menages, found brain congested, subdural hematoma over both temporal lobes.”

Further, the Court emphasized the nature of the assault, stating, “The weapon was used on the head – vital part of the body and ultimately the same proved to be fatal and the deceased died due to head injury no.1.”

Key Takeaways

• The Supreme Court emphasized the importance of considering all medical evidence, including post-mortem reports, when determining the nature of an offense.
• A conviction for murder can be upheld even if the victim dies a few days after the assault, provided the cause of death is directly linked to the injuries sustained.
• The absence of a skull fracture does not negate a murder charge if the death is caused by internal head injuries.
• The court restored the trial court’s conviction, underscoring the significance of the initial assessment of evidence.
• The judgment highlights the need for appellate courts to thoroughly review all evidence before overturning a trial court’s decision.

Directions

The Supreme Court directed that the accused, Jai Dutt and Shastri, be taken into custody forthwith to undergo life imprisonment as per the trial court’s sentence.

Development of Law

The ratio decidendi of this case is that the High Court erred in converting the conviction from Section 302 to Section 326 of the IPC based on the time of death and the absence of a skull fracture. The Supreme Court clarified that the cause of death, as determined by medical evidence, is paramount. This judgment reinforces the principle that internal injuries, especially to vital organs like the head, can constitute murder even if there is no external fracture. There is a change in the previous position of law as the High Court had reduced the conviction to Section 326 of the IPC, which was overturned by the Supreme Court.

Conclusion

The Supreme Court allowed the appeal filed by the State of Uttar Pradesh, setting aside the High Court’s judgment. The Supreme Court restored the trial court’s conviction of the accused under Section 302 of the Indian Penal Code (IPC) for murder. The court emphasized that the High Court had erred in converting the conviction based on the time of death and the absence of a skull fracture, overlooking the crucial medical evidence that clearly established the cause of death as a fatal head injury. This judgment underscores the importance of thorough consideration of medical evidence and the gravity of injuries to vital organs in determining the nature of criminal offenses.