Supreme Court Reinstates Murder Conviction: Rajasthan High Court’s Order Set Aside

The Supreme Court of India, in the case of The State of Rajasthan v. Kanhaiya Lal, overturned the Rajasthan High Court’s decision that had altered the conviction of the accused from Section 302 IPC (murder) to Section 304 Part I IPC (culpable homicide not amounting to murder). The Court reinstated the trial court’s verdict, sentencing the accused to life imprisonment.

Background of the Case

The case originated from an incident that took place on January 26, 2008. According to the prosecution, the accused, Kanhaiya Lal, attacked the victim, Raju, with an axe, striking him on the head, which resulted in Raju’s death. The attack was witnessed by PW-5 Ms. Kailashi, who raised an alarm, leading to the arrival of other people at the crime scene. The accused fled immediately after the attack.

Following the incident, a First Information Report (FIR No. 32/2008) was lodged at Nimbaheda Police Station. The investigating authorities filed a charge sheet under Section 302 IPC. The trial court, after considering the evidence, convicted Kanhaiya Lal for murder and sentenced him to life imprisonment along with a fine of Rs. 1000.

High Court’s Decision

The accused, Kanhaiya Lal, appealed against the conviction before the Rajasthan High Court. The High Court, while allowing the appeal, altered the conviction from Section 302 IPC to Section 304 Part I IPC, sentencing him to eight years of rigorous imprisonment.

Reasons Given by the High Court

• There was only a single injury inflicted on the head of the deceased.
• There was no repeated assault on the victim.
• The attack was preceded by an altercation earlier in the day.

Appeal Before the Supreme Court

The State of Rajasthan challenged the High Court’s decision before the Supreme Court, arguing that the reduction of the charge was erroneous given the facts of the case.

Arguments by the Appellant (State of Rajasthan)

• The High Court failed to consider that the accused used an axe, which is a deadly weapon, and struck the victim on the head, a vital part of the body.
• Medical evidence confirmed that the head injury was sufficient to cause death in the ordinary course of nature.
• There was no immediate provocation or altercation at the time of the attack; it was a deliberate act.
• The conversion of the conviction to Section 304 Part I IPC was manifestly erroneous.

Arguments by the Respondent (Kanhaiya Lal)

• The High Court had rightly considered the fact that there was a single blow.
• The altercation earlier in the day showed that the act was not premeditated.
• The intent was not to cause death but only to cause injury.
• The High Court’s decision was well-reasoned and did not warrant interference.

Supreme Court’s Observations

The Supreme Court, in a judgment authored by Justices L. Nageswara Rao and M.R. Shah, made the following critical observations:

1. Single Blow Rule Is Not an Absolute Principle

The Court emphasized that there is no fixed rule that a single blow can never amount to murder. It ruled:

“The nature of the weapon used and the vital part of the body where the blow was struck prove beyond reasonable doubt the intention of the accused to cause death.”

2. Use of a Deadly Weapon on a Vital Body Part Indicates Murder

The Court found that the accused deliberately used an axe, a lethal weapon, and struck the victim’s head, which proved fatal. The ruling stated:

“The accused used an axe on the head of the deceased, which is a vital organ. The act was done with full knowledge that such an injury was sufficient in the ordinary course of nature to cause death.”

3. Prior Altercation Does Not Reduce the Gravity of the Offense

The Supreme Court rejected the High Court’s reliance on the earlier altercation, stating:

“Merely because there was an altercation in the morning does not mean the accused lacked the intention to kill when he later struck the fatal blow.”

4. High Court’s Decision Was Perverse

The Court found that the High Court had committed a grave error by reducing the conviction, ruling that:

“The judgment of the High Court is manifestly perverse and is totally contrary to the evidence on record.”

Final Judgment

The Supreme Court set aside the Rajasthan High Court’s ruling and reinstated the conviction under Section 302 IPC:

“The impugned judgment of the High Court is set aside, and the conviction under Section 302 IPC is restored.”

The Court ordered Kanhaiya Lal to immediately surrender if he had been released following the High Court’s ruling.

Key Takeaways

• Single Blow Can Still Amount to Murder: The judgment reaffirms that a single fatal blow, especially on a vital part of the body, can justify a conviction for murder.
• Weapon Used and Body Part Targeted Are Critical Factors: The use of an axe to strike the head was considered sufficient to establish intent to kill.
• Previous Altercations Do Not Justify Lesser Charges: The Court clarified that a prior altercation does not diminish the intent behind a subsequent lethal attack.
• High Court’s Erroneous Interpretation Corrected: The decision highlights the importance of strictly applying the principles of criminal law to ensure justice is served.

Conclusion

The Supreme Court’s ruling in The State of Rajasthan v. Kanhaiya Lal sets a significant precedent in criminal law by reinforcing the principle that a single fatal blow can amount to murder. The decision ensures that judicial interpretation aligns with the severity of the offense and upholds the interests of justice.

Petitioner Name: The State of Rajasthan.
Respondent Name: Kanhaiya Lal.
Judgment By: Justice L. Nageswara Rao, Justice M.R. Shah.
Place Of Incident: Nimbaheda, Rajasthan.
Judgment Date: 10-04-2019.

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