Supreme Court Modifies Conviction from Section 304 Part I to Part II in Madhya Pradesh Murder Case

The Supreme Court of India recently ruled in Pop Singh & Ors. vs. State of Madhya Pradesh, modifying the conviction of the accused from Section 304 Part I of the IPC to Section 304 Part II. The case, which originated from a 1997 attack that led to the death of Jeevan Singh, involved questions of intent and the severity of injuries inflicted on the victim. The Court reduced the sentence from seven years to five years, finding that while the accused had knowledge that their actions could result in death, they did not have the intent to kill.

Background of the Case

The incident occurred on April 23, 1997, in Village Alwasa, Madhya Pradesh. The accused, armed with weapons such as axe, farsa, and dharia, attacked Jeevan Singh while he was riding his scooter to the vegetable market. The prosecution alleged that the attack was motivated by a land dispute between the accused and the deceased’s father.

Jeevan Singh sustained multiple injuries and succumbed to them four days later, on April 27, 1997. Initially, the FIR was registered under Sections 307, 147, 148, and 149 IPC, but after his death, the charges were converted to Section 302 IPC (murder).

Trial Court and High Court Findings

The trial court convicted the accused under Section 304 Part I (culpable homicide not amounting to murder with intent) and sentenced them to 10 years of rigorous imprisonment. The High Court upheld the conviction but reduced the sentence to seven years.

Arguments by the Petitioner (Pop Singh & Ors.)

The petitioners contended:

The injuries were not inflicted on vital body parts, suggesting a lack of intent to kill.
All injuries were lacerated wounds, indicating the use of the blunt side of the weapons.
Since there was no direct intent to cause death, the conviction should be altered to Section 304 Part II (culpable homicide without intent).
They had already served three years and five months of their sentence, and further imprisonment was unnecessary.

Arguments by the Respondent (State of Madhya Pradesh)

The prosecution countered these claims, stating:

The accused were armed with deadly weapons and attacked the deceased in a planned manner.
Jeevan Singh suffered nine injuries, proving that the attack was severe.
The High Court had already taken a lenient view by reducing the sentence from ten years to seven years.
The case still warranted significant punishment under Section 304 Part I.

Supreme Court’s Observations

The Supreme Court carefully analyzed the injuries, weapons used, and the intent of the accused. Key observations included:

On the Nature of Injuries:
- The injuries were lacerated wounds, which indicated the use of the blunt side of the weapons.
- The wounds were primarily on the arms and legs, not on vital organs.
On the Intent of the Accused:
- The Court ruled that the accused did not have an intention to kill but acted with knowledge that their actions could cause death.
- The accused had the opportunity to use the sharp side of their weapons but did not do so.

Key Excerpt from the Judgment

“We, therefore, find that it cannot be said that the appellants had an intention to cause the death of the deceased. However, from the nature of injuries, it is clear that the act was done with the knowledge that the injuries were likely to cause the death of the deceased.”

The Court found that while the attack was serious, it did not meet the threshold for Section 304 Part I but rather fit under Section 304 Part II, which covers acts done with knowledge but without direct intent to kill.

Final Judgment and Directions

The Supreme Court ruled:

The conviction under Section 304 Part I was modified to Section 304 Part II.
The sentence was reduced from seven years to five years of rigorous imprisonment.
The accused, having already served three years and five months, were directed to surrender within four weeks to serve the remaining sentence.

This judgment highlights the distinction between intent and knowledge in homicide cases and the importance of analyzing the nature of injuries when determining the appropriate legal provision.

Petitioner Name: Pop Singh & Ors..
Respondent Name: State of Madhya Pradesh.
Judgment By: Justice B.R. Gavai, Justice Pamidighantam Sri Narasimha.
Place Of Incident: Madhya Pradesh.
Judgment Date: 29-11-2023.

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