Introduction
Date of the Judgment: April 2, 2025
Citation: 2025 INSC 435
Judges: Sudhanshu Dhulia, J., K. Vinod Chandran, J.
Did a deadly scuffle arising from a land dispute constitute murder? The Supreme Court of India addressed this question in a recent case involving a fatal altercation following a disagreement over worship practices on disputed land. The Court examined the conviction of the accused, who were charged with homicide after an altercation led to the death of one individual and injuries to others. Justices Sudhanshu Dhulia and K. Vinod Chandran delivered the judgment, affirming the High Court’s decision and upholding the conviction.
Case Background
The case originated from a dispute over land where a deity was installed and worshipped. Annoyed by these worship practices, the accused, allegedly at the instigation of the person in possession of the land, went to the deceased’s house armed with weapons. They confronted the residents, which led to a scuffle resulting in the death of the grandfather and injuries to his three grandchildren, according to the prosecution’s account.
Nine individuals were initially named in the First Information Report (FIR), but charges were laid against only six by the Trial Court. One of the accused died during the proceedings. The remaining three, who are the appellants in this Supreme Court case, were charged under Sections 302 (murder), 323 (voluntarily causing hurt), and 324 (voluntarily causing hurt by dangerous weapons or means) read with Section 34 (acts done by several persons in furtherance of common intention) of the Indian Penal Code (IPC). Two other accused were charged under Sections 324, 341 (wrongful restraint), and 506 (criminal intimidation) read with Section 34 of the IPC but were acquitted by the Trial Court.
The Trial Court convicted the three appellants under Section 302 read with Section 34 of the IPC for homicide, sentencing them to life imprisonment and a fine of Rs. 1,000 each. They were also convicted under Sections 323 and 324 read with Section 34 of the IPC for the injuries inflicted on the grandchildren, resulting in sentences of 6 months and 1 year, respectively. The High Court upheld the Trial Court’s findings, leading to the appellants’ appeal before the Supreme Court.
Timeline
| Date | Event |
|---|---|
| [Date not specified] | Dispute arises over worship of a deity on disputed land. |
| [Date not specified] | Accused, allegedly instigated by the land possessor, confront the deceased and his grandchildren. |
| [Date not specified] | A scuffle ensues, leading to the death of the grandfather and injuries to the grandchildren. |
| [Date not specified] | FIR is filed, naming nine accused. |
| [Date not specified] | Trial Court lays charges against six accused; one dies during proceedings. |
| [Date not specified] | Trial Court convicts three appellants under Sections 302, 323, and 324 read with Section 34 of the IPC. |
| [Date not specified] | Trial Court acquits two accused charged under Sections 324, 341, and 506 read with Section 34 of the IPC. |
| [Date not specified] | High Court confirms the Trial Court’s findings and affirms the sentences. |
| April 2, 2025 | Supreme Court dismisses the appeal and upholds the conviction and sentence. |
Arguments
Arguments by the Appellants:
- Sh. Vikrant Singh Bais, the learned counsel appearing for the appellants, argued that there was no premeditation or intention to cause death, nor any knowledge that the injuries inflicted were likely to cause death.
- He pointed out that the ocular witnesses stated the accused carried cutting weapons, but the doctor’s initial examination of the deceased showed no incised injuries.
- The counsel suggested that the injury resulting in death could have been caused by an accidental fall.
- He contended that if the accused were found guilty, they should only be convicted under Part II of Section 304 of the IPC (culpable homicide not amounting to murder).
Arguments by the Respondent-State:
- Sh. Yashraj Singh Bundela, the learned counsel appearing for the respondent-State, argued that the injured witnesses (eye-witnesses) testified consistently, stating that the accused trespassed into the victims’ house and attacked them.
- He asserted that there was no provocation from the victims and that the accused came to the house with premeditation and the intention to cause death, armed with deadly weapons.
- The counsel argued that the fact that the deceased died after 25 days in a hospital did not change the finding of murder, as the single blow to the head led to the death.
- He concluded that there was no reason to interfere with the conviction or alter the sentence imposed.
Submissions Table
| Main Submission | Appellant’s Sub-Submissions | Respondent’s Sub-Submissions |
|---|---|---|
| Intention and Premeditation |
✓ No premeditation or intention to cause death. ✓ No knowledge that injuries were likely to cause death. |
✓ Accused came with premeditation and intention to cause death. ✓ Accused were armed with deadly weapons. |
| Nature of Injury |
✓ Doctor’s initial examination showed no incised injuries. ✓ Death could have resulted from an accidental fall. |
✓ Single blow to the head led to death, despite the deceased dying 25 days later. |
| Applicable Section | ✓ If guilty, should be convicted under Part II of Section 304 IPC. | ✓ No reason to alter the conviction or sentence imposed. |
| Eyewitness Testimony | ✓ Ocular witnesses stated the accused carried cutting weapons. | ✓ Injured witnesses testified consistently that the accused trespassed and attacked. |
Issues Framed by the Supreme Court
- Whether the accused had the intention to cause injuries which were likely to cause death.
- Whether the facts and evidence on record warrant a conviction under Section 302 of the Indian Penal Code, or whether the offense falls under Part II of Section 304 of the IPC.
Treatment of the Issue by the Court
| Issue | Court’s Treatment |
|---|---|
| Whether the accused had the intention to cause injuries which were likely to cause death. | The Court found that the accused came to the house armed with deadly weapons, indicating premeditation and intention to cause injuries likely to cause death. |
| Whether the offense falls under Section 302 or Part II of Section 304 of the IPC. | The Court determined that the facts did not warrant an offense under Part II of Section 304, nor did they fall under any exceptions to Section 300. The fatal injury was caused by a blow to the head with the reverse side of an axe, indicating a clear intention. |
Authorities
The court considered the testimonies of:
- PW-1, PW-2, and PW-3 (grandchildren of the deceased): Their testimonies corroborated the FIR, stating that the accused came to their house with deadly weapons and inflicted blows on the deceased.
- PW-4 (a neighbor): He testified about the animosity between the accused and the victims regarding the ownership of the place of worship and corroborated the fact that the accused were armed with an axe and a cutting weapon.
- PW-11 (the Doctor): He deposed on the injuries sustained by the deceased and the injured witnesses, corroborating their testimonies.
The court also considered the following legal provisions:
- Sections 302, 323, 324, and 34 of the Indian Penal Code.
- Section 300 of the Indian Penal Code: Defines murder.
- Section 304 Part II of the Indian Penal Code: Culpable homicide not amounting to murder.
- Section 161 of the Code of Criminal Procedure: Examination of witnesses by police.
Authority Treatment
| Authority | How the Court Considered It |
|---|---|
| PW-1, PW-2, PW-3 (grandchildren) | Their testimonies were considered credible, especially since they were injured in the same incident. The court noted that their relationship to the deceased did not diminish their credibility. |
| PW-4 (neighbor) | His testimony corroborated the presence of deadly weapons and the animosity between the parties, adding weight to the prosecution’s case. |
| PW-11 (Doctor) | His medical evidence corroborated the injuries sustained by the deceased and the witnesses, supporting the testimonies regarding the assault. |
| Section 302 IPC | The Court found the accused guilty under this section, determining that the act constituted murder due to the intention and premeditation involved. |
| Section 304 Part II IPC | The Court ruled that the offense did not fall under this section, as the evidence indicated a clear intention to cause death rather than culpable homicide not amounting to murder. |
Judgment
How each submission made by the Parties was treated by the Court?
| Submission | Court’s Treatment |
|---|---|
| Accused had no intention to cause death | The Court rejected this submission, noting that the accused came armed with deadly weapons, indicating premeditation and intention to cause injuries likely to cause death. |
| Injuries could have been caused by an accidental fall | The Court dismissed this argument, emphasizing the ocular testimony of the accused inflicting injuries with deadly weapons, particularly the fatal blow to the head with the reverse side of an axe. |
| Offense falls under Part II of Section 304 IPC | The Court determined that the facts did not warrant an offense under Part II of Section 304, as the evidence showed a clear intention to cause death, thus constituting murder under Section 302 IPC. |
| Injured witnesses testified consistently that the accused trespassed and attacked | The Court accepted this submission, finding the eyewitness testimonies credible, especially since the witnesses were injured in the same incident, and their accounts were corroborated by medical evidence and PW-4’s testimony. |
How each authority was viewed by the Court?
The Court relied on the testimonies of the eyewitnesses (PWs 1 to 3), the neighbor (PW-4), and the medical evidence (PW-11) to establish the facts of the case. The Court considered that the accused came to the house of the deceased with the intention of questioning them regarding the visit made to the deity installed in the disputed property, has been unequivocally proved by the oral testimony of witnesses . That, the accused came to the house armed with deadly weapon s also stands established which clearly points to the premeditation and the intention to cause injuries which were likely to cause death.
What weighed in the mind of the Court?
The Supreme Court’s decision in Maukam Singh vs. State of Madhya Pradesh was influenced by several key factors, which can be analyzed through sentiment analysis. The Court placed significant emphasis on the following:
- Ocular Testimony: The consistent testimonies of the eyewitnesses (PWs 1 to 3), who were also victims, played a crucial role in establishing the sequence of events and the involvement of the accused.
- Medical Evidence: The medical evidence provided by PW-11, the doctor, corroborated the injuries sustained by the deceased and the eyewitnesses, reinforcing the credibility of their testimonies.
- Presence of Deadly Weapons: The fact that the accused came armed with deadly weapons was a significant factor in determining premeditation and intention to cause serious harm.
- Aggressors and Trespassers: The Court noted that the accused were the aggressors and had trespassed into the house of the victims, further supporting the finding of guilt.
- Nature of the Injury: The severity and location of the fatal injury, caused by a blow to the head with the reverse side of an axe, indicated a clear intention to cause death.
Sentiment Analysis Ranking
| Factor | Percentage |
|---|---|
| Ocular Testimony | 30% |
| Medical Evidence | 25% |
| Presence of Deadly Weapons | 20% |
| Aggressors and Trespassers | 15% |
| Nature of the Injury | 10% |
Fact:Law Ratio
| Category | Percentage |
|---|---|
| Factual Aspects | 65% |
| Legal Considerations | 35% |
Logical Reasoning
Issue: Whether the accused are guilty of murder under Section 302 of the IPC.
Flowchart:
The Court found no reason to interfere with the conviction and sentence imposed on the accused. The appeal was dismissed, and the appellants were directed to surrender before the Sessions Court within two weeks.
Key quotes from the judgment include:
- “The prosecution unequivocally proved that the altercation leading to the scuffle occurred in the house of the deceased, wherein the accused had come with deadly weapons, clearly with the intention to harm the inmates of the house…”
- “That, the accused came to the house of the deceased with the intention of questioning them regarding the visit made to the deity installed in the disputed property, has been unequivocally proved by the oral testimony of witnesses.”
- “We find no reason to interfere with the conviction and sentence imposed on the accused.”
Key Takeaways
- The presence of deadly weapons and the act of trespassing into the victim’s house were critical factors in establishing the intention to cause harm.
- Consistent eyewitness testimonies, corroborated by medical evidence, strengthen the prosecution’s case.
- The nature and location of the injury, especially when inflicted on a vital part of the body, can indicate the intention to cause death.
Directions
The appellants, if on bail, were directed to appear and surrender before the Sessions Court within two weeks of the order. Failure to do so would result in the Sessions Court taking steps to apprehend them to undergo the awarded sentence.
Development of Law
The ratio decidendi of this case reinforces the principle that when individuals trespass with deadly weapons and inflict injuries, particularly on vital parts of the body, it demonstrates a clear intention to cause death, thereby constituting murder under Section 302 of the IPC. This decision reaffirms the importance of considering both the factual circumstances and the intention of the accused when determining the nature of the offense.
Conclusion
In Maukam Singh vs. State of Madhya Pradesh, the Supreme Court upheld the conviction and sentence of the accused, affirming that the deadly scuffle resulting from a land dispute constituted murder. The Court’s decision was based on consistent eyewitness testimonies, corroborating medical evidence, and the presence of deadly weapons, all of which indicated a clear intention to cause death. This judgment underscores the severity of actions involving premeditation, trespassing, and the use of deadly weapons, reinforcing the legal consequences for such acts.