Supreme Court Restores Murder Conviction in Madhya Pradesh Assault Case

The Supreme Court of India, in the case State of Madhya Pradesh vs. Goloo Raikwar and Anr., addressed the issue of appropriate sentencing in a brutal assault case that led to the death of Hari Choudhary. The Court revisited the conviction of the respondents, who were originally charged under Section 302 of the Indian Penal Code (IPC) for murder. The High Court had altered the conviction to Section 304-I, reducing the sentence, but the Supreme Court reversed this decision, restoring the original conviction for murder and reaffirming the importance of appropriate sentencing for intentional acts of violence.

Background of the Case

The case arose from a violent attack on Hari Choudhary, who was assaulted by five accused, including Goloo Raikwar and Bhura Raikwar. The attack occurred on 15th August 2000 when Hari and his nephew Kallu Choudhary were on their way to eat betel. The accused, armed with weapons, ambushed the two, with Bhura throwing a country bomb at them. As the explosion occurred, Bhura struck Hari with a sword, and the other accused attacked him with various weapons. Hari succumbed to his injuries and was declared dead upon arrival at the hospital.

The trial court had initially convicted the accused under Section 302 of the IPC for murder, but the High Court reduced the charges to Section 304-I, culpable homicide not amounting to murder, and lowered the sentence to ten years of rigorous imprisonment.

The State of Madhya Pradesh filed an appeal before the Supreme Court, challenging the leniency of the sentence and seeking a higher punishment for the convicted individuals.

Petitioner’s (State of Madhya Pradesh) Arguments:

• The petitioner argued that the High Court had been overly lenient in its sentencing, considering the gravity of the injuries caused to the complainant.
• The appellant emphasized that the attack had been premeditated, and the nature of the weapons used—specifically the farsa and iron rod—indicated an intent to cause grievous harm or even death.
• The petitioner contended that the sentence should be increased to reflect the seriousness of the assault and to act as a deterrent for such crimes.

Respondent’s (Goloo Raikwar and Bhura Raikwar) Arguments:

• The respondents argued that the High Court had correctly modified the charges based on the nature of the injuries, which they claimed were not sufficient to establish the intent to commit murder.
• The defense counsel emphasized that while the injuries were severe, there was no evidence to suggest that the accused had the intention to commit murder.
• The respondents further argued that they should be sentenced under Section 304-I, as the attack was not premeditated with the intention to kill.

Supreme Court’s Judgment:

• The Supreme Court, after reviewing the facts and medical evidence, concluded that the injuries inflicted on the deceased were sufficient to cause death in the ordinary course of nature.
• The Court held that while the respondents may not have intended to kill, their actions were premeditated and aimed at inflicting grievous harm, which led to the death of the victim.
• The Court noted, “The mere fact that the beating was confined to the legs and arms or that none of the multiple injuries inflicted was individually sufficient to cause death will not exclude the application of clause thirdly of Section 300 of the IPC.”
• The Court relied on the ruling in State of Andhra Pradesh vs. Rayavarapu Punnayya and Anr., where it was held that multiple injuries intended to cause bodily harm, even if not individually fatal, could cumulatively be sufficient to establish the intent to commit murder.
• In light of this reasoning, the Supreme Court overturned the High Court’s judgment and restored the original conviction for murder under Section 302 of the IPC.
• The Court directed the respondents to surrender before the trial court to serve the remaining sentence, failing which arrest warrants would be issued.

Key Takeaways

• The judgment reaffirms the importance of proper sentencing for intentional acts of violence, even when the injuries are not inflicted on vital organs.
• The ruling underscores the importance of premeditation in establishing the intent to commit murder, even when the attack does not result in immediate death.
• The decision highlights the importance of restoring convictions that accurately reflect the severity of the offense.

The judgment was delivered by Justice Jagdish Singh Khehar and Justice C. Nagappan on March 2, 2016.

This decision reinforces the principle that justice must be served based on the severity of the crime and ensures that those who commit violent acts that result in death face appropriate punishment.

Don’t miss out on the full details! Download the complete judgment in PDF format below and gain valuable insights instantly!

Download Judgment: State of Madhya Prad vs Goloo Raikwar and Bh Supreme Court of India Judgment Dated 02-03-2016-1741853818206.pdf