Acquittal of Karuppanna Gounder: Supreme Court Revisits Conviction Under IPC 302

The case of Karuppanna Gounder v. The State Rep. by The Inspector of Police is a significant judgment dealing with a criminal appeal under Section 302 of the Indian Penal Code (IPC). The appellant was initially convicted of murder by the Trial Court, which was upheld by the High Court of Madras. However, the Supreme Court re-examined the evidence and modified the sentence, ultimately acquitting the appellant of the murder charge.

Background of the Case

Chinnappa Gounder, the deceased, was a neighbor of the appellant, Karuppanna Gounder. Both had adjacent properties and shared a well divided by a wall. Disputes arose regarding repairs to the well, leading to an altercation on July 17, 2000. During the quarrel, Karuppanna Gounder allegedly struck Chinnappa Gounder with a hammer, and other accused individuals also attacked him with weapons, including a sickle and iron rods. The victim succumbed to injuries in the hospital.

Trial Court and High Court Decisions

The Trial Court convicted Karuppanna Gounder under IPC Section 302 and sentenced him to life imprisonment. Rajendran, the appellant’s son-in-law, was also found guilty. However, the High Court reduced Rajendran’s conviction, noting that the injury caused by him did not match the description of a sharp weapon wound. The High Court upheld Karuppanna Gounder’s life imprisonment.

Supreme Court’s Observations

The Supreme Court focused on medical evidence and witness testimonies. The post-mortem report recorded multiple injuries, with two key injuries being a 10×2 cm laceration in the parietal area and a compound skull fracture exposing brain matter. The Court found that the alleged injury inflicted by Karuppanna Gounder with a hammer did not correspond to the fatal injuries in the report.

Judgment and Rationale

The Court stated: “The appellant is alleged to have used the Sammatti (hammer) and gave a blow at the back of the head or the neck of the deceased. Both the injuries do not correspond with the injury of the back of the head or neck.”

Furthermore, since co-accused Rajendran was acquitted of murder, the appellant could not be convicted under Sections 34 or 149 IPC. The Supreme Court concluded that the appellant’s act did not directly cause the victim’s death. Instead, he was convicted under Section 324 IPC (voluntarily causing hurt with a dangerous weapon) and sentenced to the period already undergone in custody.

Final Verdict

The Supreme Court modified the sentence, acquitting the appellant of murder but convicting him under Section 324 IPC. His bail bonds were discharged, and the appeal was partially allowed.

Key Takeaways:

• Medical evidence plays a crucial role in determining the cause of death.
• Conviction under IPC 302 requires a clear causal link between the accused’s act and the fatal injury.
• The Court provided the benefit of the doubt in the absence of conclusive evidence linking the appellant to the fatal blow.

This judgment reinforces the principle that criminal liability must be established beyond a reasonable doubt, ensuring fair trial rights for the accused.

Petitioner Name: Karuppanna Gounder.
Respondent Name: The State Rep. by The Inspector of Police.
Judgment By: Justice Deepak Gupta, Justice Aniruddha Bose.
Place Of Incident: Tamil Nadu.
Judgment Date: 17-09-2019.

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