Supreme Court Modifies Conviction in Rajasthan Murder Case: Culpable Homicide Not Amounting to Murder

The Supreme Court of India recently delivered a significant judgment in the case of Sita Ram & Ors. vs. State of Rajasthan, where it modified the conviction of the accused from murder to culpable homicide not amounting to murder. This ruling altered the sentences of the convicted individuals based on the circumstances surrounding the case.

The appeal was filed against the judgment of the Rajasthan High Court, which had upheld the conviction of eight individuals for murder under Section 302 of the Indian Penal Code (IPC). The Supreme Court, after reviewing the facts and circumstances of the case, concluded that the act fell under Exception 4 to Section 300 IPC and, therefore, amounted to culpable homicide not amounting to murder.

Background of the Case

The case dates back to August 2, 1982, when an incident occurred in an agricultural field at Khasra No. 210 in Rajasthan. The complainant, Moti Ram, reported that his mother and wife, along with his brother Phoolchand, had gone to the field when a group of people armed with sickles and cudgels attacked them. His younger brother ran back home to inform his father, Ghadsee Ram, and his other brother, Shyam Lal. When they arrived at the scene, the assailants also attacked them, leading to severe injuries. Eventually, Ghadsee Ram succumbed to his injuries.

Initially, the police registered the crime under Sections 147, 148, 325, 324, 323, 149 read with 382 IPC. However, after the death of Ghadsee Ram, the offense under Section 302 IPC was added.

Medical Findings and Evidence

According to the post-mortem conducted by Dr. M.M. Mishra, the deceased Ghadsee Ram had multiple injuries, including a skull fracture, subdural hematoma, and lacerations on the brain. The report confirmed that the injuries were caused by blunt objects, such as lathis, and were sufficient to cause death in the ordinary course of nature.

The medical report also highlighted that Meera, the wife of the complainant, and Barji, the mother of the complainant, had sustained injuries. In contrast, two accused persons, Jagdish and Prahlad, also suffered injuries, some caused by sharp cutting weapons.

Petitioner’s Arguments

The appellants contended that the incident occurred as part of a land dispute and was not a premeditated murder. They argued that:

The injuries were caused by blunt objects and not by lethal weapons.
There was a history of land disputes between the parties, which led to an altercation.
The injuries suffered by the accused indicated that there was a fight, and it was not a one-sided attack.
The case should be considered under the Exception 4 of Section 300 IPC, reducing it from murder to culpable homicide not amounting to murder.

Respondent’s Arguments

The prosecution maintained that the accused had formed an unlawful assembly and carried out a brutal attack, resulting in the death of Ghadsee Ram. They asserted that:

The nature and number of injuries demonstrated a clear intention to cause death.
The accused were armed and attacked the victims without provocation.
The Trial Court and High Court correctly convicted the accused under Section 302 IPC.

Supreme Court’s Analysis

The Supreme Court examined the evidence and found that:

The deceased suffered injuries from blunt objects, not sharp weapons.
The land where the incident occurred was disputed.
Some accused individuals had also sustained injuries.
The altercation began as a verbal exchange and escalated into physical violence.

Considering these factors, the Court concluded that the case fell under Exception 4 to Section 300 IPC, which states that culpable homicide is not murder if it occurs due to a sudden fight without premeditation and in the heat of passion.

The Court stated:

“In the premises, in our considered view, the matter would be covered by Exception fourthly to Section 300 IPC and as such, the crime in question would not be ‘murder’ but ‘culpable homicide not amounting to murder’.”

Judgment and Conclusion

The Supreme Court allowed the appeal to the extent that the conviction under Section 302 IPC was modified to Section 304-II IPC (culpable homicide not amounting to murder). The Court sentenced the convicted individuals to six years of imprisonment, considering they had already served a significant part of their sentence.

Furthermore, two of the accused, Prahlad and Ganesh, were found to be juveniles at the time of the incident. The Court directed that they be dealt with under the Juvenile Justice Act.

This judgment highlights the importance of analyzing each case based on its specific facts and circumstances. The Supreme Court reaffirmed that the intention behind an act plays a crucial role in determining the severity of the offense.

Judges: The judgment was delivered by Uday Umesh Lalit, S. Ravindra Bhat, and Bela M. Trivedi.

Petition Result: Partially Allowed

Petitioner Name: Sita Ram & Ors..
Respondent Name: State of Rajasthan.
Judgment By: Justice Uday Umesh Lalit, Justice S. Ravindra Bhat, Justice Bela M. Trivedi.
Place Of Incident: Rajasthan.
Judgment Date: 28-10-2021.

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