Haryana Factory Explosion: Supreme Court Upholds Downgrade of Murder Charges
The case of State of Haryana vs. Rajesh Aggarwal & Anr. revolved around a tragic factory explosion at M/s Kee Pharma Private Limited, resulting in the deaths of seven workers. The Supreme Court upheld the Punjab and Haryana High Court’s decision to downgrade the charges against the accused from murder (Section 302 IPC) to causing death by negligence (Section 304-A IPC).
Background of the Case
On 27th June 1996, a chemical blast occurred at the Gurgaon-based pharmaceutical factory, leading to widespread smoke and a stampede. Forty-five workers were present at the time, and in the ensuing chaos, seven lost their lives.
The factory directors, Rajesh Aggarwal and another, were charged under Section 302 IPC, alleging that their negligence was tantamount to murder. They challenged this charge, seeking its alteration to Section 304-A IPC, arguing that their liability was due to negligence rather than intentional homicide.
Arguments Presented
Prosecution’s Argument
- The accused were responsible for the factory’s daily operations.
- The explosion was caused by their negligence in maintaining safety standards.
- Since their actions led to the deaths of workers, a charge under Section 302 IPC (murder) was justified.
Defense’s Stand
- The incident was an industrial accident, not an intentional act.
- There was no direct evidence suggesting premeditation or intent to kill.
- The appropriate charge should be Section 304-A IPC (causing death by negligence), not Section 302 IPC.
High Court’s Ruling
The Punjab and Haryana High Court partially allowed the accused’s plea, altering the charge from Section 302 IPC to Section 304-A IPC. The court held:
“There is no material on record to suggest that the respondents had any intention to kill the workers or that they had knowledge that their acts would result in certain death.”
Supreme Court’s Verdict
The Supreme Court upheld the High Court’s decision, reasoning:
“The reasoning and conclusion arrived at by the High Court for altering the charge for the offence from Section 302 to Section 304-A IPC at this stage cannot be faulted.”
The Court further observed:
“Depending upon the evidence adduced by the prosecution, the Sessions Judge has ample power to alter, amend, or add any charge by taking recourse to powers under Section 216 of the Cr.P.C.”
The Court directed the Sessions Judge to complete the trial within one year and lifted the interim stay.
Legal Significance
This judgment clarifies the distinction between criminal negligence and murder in industrial accidents. The ruling reinforces the principle that without intent or knowledge leading to certain death, a murder charge under Section 302 IPC is not justified.
Conclusion
The Supreme Court’s decision ensures a fair legal assessment of the accused’s liability, focusing on negligence rather than intent. The ruling serves as an important precedent in cases of industrial accidents where culpability is based on negligence rather than criminal intent.
Petitioner Name: State of Haryana.Respondent Name: Rajesh Aggarwal & Anr..Judgment By: Justice Abhay Manohar Sapre, Justice Sanjay Kishan Kaul.Place Of Incident: Gurgaon, Haryana.Judgment Date: 20-08-2018.
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