Kunhimuhammed vs. State of Kerala: Supreme Court Upholds Murder Conviction

The case of Kunhimuhammed @ Kunheethu vs. State of Kerala is a significant Supreme Court ruling that deals with the interpretation of culpable homicide and murder under the Indian Penal Code (IPC). The case involves the conviction of the appellant under Section 302 IPC for a politically motivated killing. The central issue before the Supreme Court was whether the appellant’s conviction for murder should be upheld or whether the offense should be classified as culpable homicide not amounting to murder under Section 304 IPC.

Background of the Case

The case arises from a political altercation between supporters of the United Democratic Front (UDF) and the Left Democratic Front (LDF) in Kerala. The dispute escalated on April 10, 2006, when a violent clash occurred between the rival groups. The following day, April 11, 2006, the appellant, along with others, launched an attack on two individuals, Subrahmannian (the deceased) and Vasudevan Ramachandra (CW-1), at Mukkilaplavu Junction. The deceased was stabbed multiple times, leading to his death.

Trial Court’s Findings

The Sessions Court found the appellant guilty of murder (Section 302 IPC), causing grievous hurt (Section 326 IPC), and causing hurt (Section 324 IPC). The sentences imposed were:

Life imprisonment under Section 302 IPC along with a fine of ₹1 lakh.
Six years rigorous imprisonment under Section 326 IPC with a fine of ₹25,000.
Two years imprisonment under Section 324 IPC.

Accused no.2 and no.3 were convicted of causing grievous hurt under Section 326 IPC and sentenced to six years imprisonment, which was later reduced on appeal.

High Court’s Decision

The Kerala High Court upheld the conviction and sentence, rejecting the appellant’s plea to reduce the conviction to culpable homicide not amounting to murder under Section 304 IPC.

Arguments by the Appellant

The appellant’s counsel contended that:

The act was not premeditated but a result of a spontaneous political altercation.
The appellant had initially used a stick, and only later resorted to a knife in self-defense.
The injuries inflicted were not with an intention to kill, making it a case of culpable homicide not amounting to murder.
The appellant was 67 years old and suffered from multiple health ailments, which should be considered in sentencing.

Arguments by the Respondent

The State of Kerala argued that:

The attack was deliberate and well-planned, as evidenced by the multiple stab wounds inflicted on the deceased.
The appellant was armed with a knife, proving premeditation.
The medical evidence confirmed that the fatal injuries were inflicted on vital organs such as the heart and lungs, establishing clear intent to kill.

Supreme Court’s Analysis

The Supreme Court analyzed the testimonies of key witnesses, forensic reports, and previous rulings to determine whether the appellant’s act constituted murder or culpable homicide. The Court observed:

The testimony of CW-1, the injured eyewitness, was consistent and corroborated by medical evidence.
The post-mortem report confirmed multiple stab wounds on the deceased’s chest, heart, and lungs.
The forensic report established that the knife used bore the deceased’s blood, proving its role in the crime.

The Court stated:

“The deliberate targeting of vital organs with a sharp weapon indicates a clear intent to cause death.”

Final Judgment

The Supreme Court ruled that:

The appellant’s actions fell within the definition of murder under Section 300 IPC, making it a case of murder rather than culpable homicide.
The appellant’s plea of self-defense was unsubstantiated, and the attack was found to be deliberate and intentional.
The conviction and sentence of life imprisonment were upheld.

Conclusion

This judgment reinforces the principle that intentional and fatal attacks with weapons fall under murder rather than culpable homicide. The ruling upholds the distinction between spontaneous altercations and premeditated lethal assaults, ensuring that grave offenses receive appropriate legal consequences.

Petitioner Name: Kunhimuhammed @ Kunheethu.
Respondent Name: State of Kerala.
Judgment By: Justice Vikram Nath, Justice Prasanna B. Varale.
Place Of Incident: Kerala.
Judgment Date: 05-12-2024.

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