Featured image for Supreme Court Judgment dated 14-02-2017 in case of petitioner name Arjun & Others vs State of Chhattisgarh
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Supreme Court Modifies Conviction in Murder Case: Arjun vs. State of Chhattisgarh

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The Supreme Court of India, in its judgment dated February 14, 2017, modified the conviction of Arjun and others from Section 302 IPC (murder) to Section 304 Part I IPC (culpable homicide not amounting to murder). The appeal arose from the Chhattisgarh High Court’s decision, which had upheld the trial court’s verdict convicting the accused of murder and sentencing them to life imprisonment.

Background of the Case

The case stemmed from a land dispute in the village of Ghatmadwa, Chhattisgarh. On November 19, 2006, at around 9:45 AM, the deceased, Ayodhya Prasad alias Rahasu, was cutting a tree on his land when the accused—Arjun, Lalaram, and Padumlal—objected to the tree-cutting. The altercation escalated, and the accused attacked the deceased with weapons, including a katta (cutting weapon), gandasa (axe), and a stone. Ayodhya Prasad sustained severe head injuries, causing his brain matter to be exposed, and he succumbed to his injuries while being transported to the hospital.

Trial Court’s Verdict

The prosecution presented twelve witnesses, including eye-witnesses Bajrang Manjhi (PW-1), Borri Verma (PW-2), Gilli Raout (PW-7), and Makunda Raout (PW-8), who were present at the scene. The prosecution argued that the accused had acted with a common intention to murder the deceased.

Based on the evidence, the trial court convicted the accused under Section 302 IPC (murder) and sentenced them to life imprisonment with a fine of Rs. 20,000. In default of payment, they were required to undergo two years of rigorous imprisonment.

High Court’s Judgment

The accused appealed to the Chhattisgarh High Court, arguing that the conviction was erroneous and not supported by evidence. The High Court dismissed the appeal and affirmed the trial court’s ruling, holding that:

  • The presence of the accused at the crime scene was established.
  • The accused were armed and attacked the deceased with lethal weapons.
  • The injuries sustained by the deceased were consistent with the prosecution’s case.
  • The common intention of the accused to commit murder was evident from their actions.

Petitioner’s (Accused’s) Arguments

Before the Supreme Court, the appellants contended:

  • There was no premeditation; the incident was a sudden altercation.
  • The deceased was trespassing on the accused’s land, leading to a confrontation.
  • The prosecution failed to establish the accused’s intent to kill.
  • PW-6 Shivprasad (brother of the deceased) was an interested witness, and his testimony should not be solely relied upon.
  • The last-minute inclusion of Arjun as an accused was not supported by original witness statements.

Respondent’s (State of Chhattisgarh) Arguments

The prosecution countered by asserting:

  • The accused used dangerous weapons and attacked the victim on a vulnerable body part (head), indicating intent to kill.
  • The testimony of multiple eye-witnesses corroborated the prosecution’s version of events.
  • The injuries and forensic evidence matched the cause of death as opined by Dr. Harnath Verma (PW-12).
  • Even if the attack was sudden, the accused’s conduct after the assault showed no remorse or attempt to provide medical assistance.

Supreme Court’s Observations

Justice R. Banumathi, delivering the judgment, made key observations:

“The occurrence must have been sudden and unpremeditated, and the offender must not have taken any undue advantage or acted in a cruel manner.”

“The accused, as per the sequence of events, had weapons in their hands, but the weapons were used in a sudden fight, with no premeditation.”

The Court applied Exception 4 to Section 300 IPC, which states that culpable homicide does not amount to murder when the act is committed:

  • Without premeditation.
  • In a sudden fight.
  • Without taking undue advantage.
  • Without acting in a cruel or unusual manner.

The Court found that the accused did not plan the attack and acted in the heat of the moment during a property dispute.

Final Verdict

The Supreme Court modified the conviction as follows:

  • The conviction under Section 302 IPC was altered to Section 304 Part I IPC (culpable homicide not amounting to murder).
  • The life imprisonment sentence was reduced to the period already served.
  • The accused were ordered to be released immediately unless required in other cases.

Impact of the Judgment

  • The ruling emphasized that not all deaths caused in a sudden fight qualify as murder.
  • The judgment reinforced the need for courts to assess intent and provocation in homicide cases.
  • The case set a precedent for applying Exception 4 to Section 300 IPC in property and land disputes.

Conclusion

The Supreme Court’s decision in Arjun vs. State of Chhattisgarh serves as a critical precedent in criminal jurisprudence, distinguishing between murder and culpable homicide. By applying Exception 4 to Section 300 IPC, the Court balanced the legal framework with the realities of sudden altercations, ensuring justice was served.

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