Supreme Court Upholds Murder Conviction, Rules Out Culpable Homicide in Madhya Pradesh Case (7 September 2022)

Introduction

Date of the Judgment: 7 September 2022
Citation: Not Available
Judges: Justice Dinesh Maheshwari and Justice Bela M. Trivedi

When does a fight become murder? The Supreme Court recently addressed this critical question in a case from Madhya Pradesh, examining whether a fatal assault constituted murder or culpable homicide not amounting to murder. The court had to determine if the act was a sudden fight or a premeditated attack, and whether the accused intended to cause death. This judgment clarifies the circumstances under which an act of violence can be classified as murder under Section 302 of the Indian Penal Code, 1860, and when it might fall under the exception of culpable homicide not amounting to murder under Section 304 of the Indian Penal Code, 1860. The bench comprised Justice Dinesh Maheshwari and Justice Bela M. Trivedi, who delivered a unanimous verdict, dismissing the appeals of the accused.

Case Background

The case revolves around an incident where the appellants, Pillu @ Prahlad and another, were accused of assaulting and causing the death of one Sanju. The prosecution’s case was that the appellants had pressured Sanju to refrain from giving evidence in another criminal case. When Sanju refused, they assaulted him, leading to his death. The prosecution presented two key witnesses: PW-1 Shankerlal, who was also injured in the incident, and PW-11 Rameshwar Prasad, who claimed to be an eyewitness. The appellants were convicted by the trial court, and the High Court of Madhya Pradesh upheld their conviction.

Timeline

Course of Proceedings

The Trial Court convicted the appellants under Section 302/34 of the Indian Penal Code, 1860, sentencing them to life imprisonment. The appellants then appealed to the High Court of Madhya Pradesh at Jabalpur. The High Court dismissed their appeal, upholding the trial court’s decision. This led to the appellants filing an appeal before the Supreme Court of India.

Legal Framework

The primary legal provisions at the heart of this case are Sections 300 and 302 of the Indian Penal Code, 1860, which define murder and prescribe its punishment. Section 300 of the Indian Penal Code, 1860 defines murder, while Section 302 of the Indian Penal Code, 1860 prescribes the punishment for murder. Exception 4 to Section 300 of the Indian Penal Code, 1860 states that culpable homicide is not murder if it is committed without premeditation in a sudden fight in the heat of passion upon a sudden quarrel and without the offender having taken undue advantage or acted in a cruel or unusual manner. The core issue was whether the appellants’ actions fell under the definition of murder or whether they could be considered culpable homicide not amounting to murder due to the presence of a sudden fight.

The relevant provisions are:

• Section 300 of the Indian Penal Code, 1860: Defines murder.
• Section 302 of the Indian Penal Code, 1860: Prescribes the punishment for murder.
• Exception 4 to Section 300 of the Indian Penal Code, 1860: States that culpable homicide is not murder if it is committed without premeditation in a sudden fight in the heat of passion upon a sudden quarrel and without the offender having taken undue advantage or acted in a cruel or unusual manner.

Arguments

Appellants’ Arguments:

• The appellants argued that the prosecution witnesses, PW-1 Shankerlal and PW-11 Rameshwar Prasad, were not reliable. PW-1 was declared hostile and did not fully support the prosecution’s case. PW-11 was introduced as an eyewitness 22 days after the FIR was lodged, raising doubts about his credibility.
• Even if the prosecution’s case was taken at face value, the offense would not amount to murder but culpable homicide not amounting to murder, as it would fall under Exception 4 to Section 300 of the Indian Penal Code, 1860. The appellants relied on the case of Pulicherla Nagaraju Alias Nagaraja Reddy v. State of A.P. (2006) 11 SCC 444, where the court discussed the factors determining the intention to cause death.
• The appellants contended that the incident was a sudden fight without premeditation, and there was no intention to cause death.

Respondent’s Arguments:

• The respondent argued that the trial court and the High Court had thoroughly examined the evidence, including the testimonies of PW-1 and PW-11, before concluding the appellants’ guilt.
• The respondent submitted that Exception 4 to Section 300 of the Indian Penal Code, 1860, did not apply because the incident was not a sudden fight. According to the witnesses, the appellants had tried to pressure the victim to refrain from giving evidence in another case and then assaulted him.
• The respondent highlighted the nature of the injuries sustained by the deceased, including multiple incise wounds and stab wounds, indicating an intention to cause death.

Issues Framed by the Supreme Court

The Supreme Court did not explicitly frame specific issues but addressed the core question of whether the appellants were guilty of murder under Section 302 of the Indian Penal Code, 1860 or culpable homicide not amounting to murder under Section 304 of the Indian Penal Code, 1860, and whether Exception 4 to Section 300 of the Indian Penal Code, 1860 was applicable.

Treatment of the Issue by the Court

Authorities

The Supreme Court considered the following authorities:

• Pulicherla Nagaraju Alias Nagaraja Reddy v. State of A.P. (2006) 11 SCC 444 – The Supreme Court of India discussed the factors determining the intention to cause death.
• Section 300 of the Indian Penal Code, 1860: Defines murder.
• Section 302 of the Indian Penal Code, 1860: Prescribes the punishment for murder.
• Exception 4 to Section 300 of the Indian Penal Code, 1860: States that culpable homicide is not murder if it is committed without premeditation in a sudden fight in the heat of passion upon a sudden quarrel and without the offender having taken undue advantage or acted in a cruel or unusual manner.

Judgment

How each authority was viewed by the Court?

• The Court referred to Pulicherla Nagaraju Alias Nagaraja Reddy v. State of A.P. [2006] 11 SCC 444* to understand the factors determining the intention to cause death, but distinguished it based on the facts of the present case.
• The Court applied Section 300 of the Indian Penal Code, 1860 to define murder and Section 302 of the Indian Penal Code, 1860 to prescribe the punishment for murder.
• The Court considered Exception 4 to Section 300 of the Indian Penal Code, 1860 but ruled it out, stating that the incident was not a sudden fight.

What weighed in the mind of the Court?

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

• The concurrent findings of fact by the Trial Court and the High Court regarding the involvement of the appellants in the incident.
• The reliability of the prosecution witnesses, particularly PW-1 and PW-11, whose testimonies were found credible after thorough examination.
• The nature of the incident, which was not a sudden fight but an assault following an attempt to pressurize the victim.
• The nature of the injuries sustained by the deceased, including multiple incise wounds and stab wounds, indicating an intention to cause death.

The Court’s reasoning was a mix of factual analysis and legal interpretation. The court emphasized the factual findings of the lower courts and the credibility of the witnesses. The legal interpretation focused on the inapplicability of Exception 4 to Section 300 of the Indian Penal Code, 1860, given the nature of the incident and the injuries sustained by the deceased.

Logical Reasoning:

The Supreme Court rejected the appellants’ argument that the case fell under Exception 4 to Section 300 of the Indian Penal Code, 1860. The Court reasoned that the incident was not a sudden fight, but an assault following an attempt to pressurize the victim. The nature of the injuries also indicated an intention to cause death, ruling out the possibility of culpable homicide not amounting to murder.

The court’s decision was based on a thorough examination of the facts and evidence, as well as a careful application of the relevant legal provisions. The court considered the arguments presented by both sides but ultimately found the prosecution’s case to be more convincing. The court also emphasized the importance of the findings of the lower courts, which had also found the appellants guilty of murder.

Key Takeaways

• Importance of Witness Credibility: The Supreme Court emphasized the importance of the credibility of witnesses in criminal cases. The court upheld the findings of the lower courts, which had found the testimonies of PW-1 and PW-11 to be reliable.
• Interpretation of Exception 4 to Section 300 of the Indian Penal Code, 1860: The judgment clarifies the interpretation of Exception 4 to Section 300 of the Indian Penal Code, 1860, stating that it applies only to cases of sudden fights without premeditation. The court ruled that the present case did not fall under this exception because the incident was not a sudden fight but an assault following an attempt to pressurize the victim.
• Nature of Injuries: The court also emphasized the importance of the nature of injuries in determining the intention of the accused. The multiple incise wounds and stab wounds on the deceased indicated an intention to cause death, ruling out the possibility of culpable homicide not amounting to murder.

Directions

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

Specific Amendments Analysis

There is no discussion of any specific amendments in this judgment.

Development of Law

The ratio decidendi of this case is that the applicability of Exception 4 to Section 300 of the Indian Penal Code, 1860 is limited to cases of sudden fights without premeditation. The court’s emphasis on the nature of the incident and the injuries sustained by the deceased serves as a guide for future cases involving similar circumstances. This judgment reinforces the importance of witness credibility and the need for a thorough examination of evidence in criminal cases. There is no change in the previous positions of law.

Conclusion

The Supreme Court dismissed the appeals, upholding the conviction of the appellants for murder under Section 302 of the Indian Penal Code, 1860. The Court ruled out the applicability of Exception 4 to Section 300 of the Indian Penal Code, 1860, stating that the incident was not a sudden fight and the injuries indicated an intention to cause death. The judgment reinforces the importance of witness credibility and the need for a thorough examination of evidence in criminal cases.