Acts and Sections Discussed:

• Indian Penal Code, 1860 (IPC)
  • Section 302 – Punishment for Murder
  • Section 304 Part I – Culpable Homicide not amounting to Murder
  • Section 307 – Attempt to Murder
• Code of Criminal Procedure, 1973 (CrPC)
  • Section 145 – Dispute concerning land or water likely to cause breach of peace

Ratio: In cases involving longstanding enmity and sudden quarrels, where the intent to kill cannot be established beyond reasonable doubt, the conviction may be downgraded from murder under Section 302 to culpable homicide under Section 304 Part I.

Background and Introduction (Paras 1-2)

The appellants challenged the judgment of the Chhattisgarh High Court (dated October 4, 2010) in which their conviction under Section 302 IPC was upheld. The incident in question involved an assault leading to the death of one Bahal, a case rooted in a longstanding land dispute between the appellants and the deceased.

Incident Details and FIR (Para 2.1)

On December 20, 2002, Dhannu Das (PW-2) witnessed the appellants assaulting Bahal near his shop. The police registered an FIR under Section 307 read with Section 34 IPC, which was later amended to Section 302 IPC after Bahal's death.

Background Dispute (Para 2.2)

A land dispute had been ongoing between the families of the deceased and the appellants. A few days prior, the Sub-Divisional Magistrate closed related proceedings, directing maintenance of the status quo in favor of the appellants.

Day of the Incident (Para 2.3)

On December 20, 2002, while the deceased was discussing the dispute with the village Sarpanch, the appellants approached, threatened him, and attacked with sticks, a rod, and an axe. His mother (PW-1) tried to intervene, but both sustained injuries. Bahal succumbed to his injuries later that day.

Medical Findings (Para 2.4)

The post-mortem revealed that the cause of death was a brain injury resulting from head trauma.

Trial Proceedings (Paras 2.5-2.9)

The trial court convicted the appellants under Section 302 IPC, sentencing them to life imprisonment. This conviction was upheld by the High Court, leading to the present appeal.

Arguments by Amicus Curiae (Paras 5-6)

The appellants argued that the incident stemmed from a sudden quarrel, influenced by longstanding enmity. It was suggested that the offense should fall under Section 304 IPC instead of Section 302 IPC, as the attack was not premeditated.

Prosecution’s Standpoint (Paras 7-9)

The State contended that the conviction under Section 302 IPC was appropriate, citing direct evidence and the corroborated accounts of multiple eyewitnesses.

Analysis and Findings (Paras 10-20)

Cause of Death and Eyewitnesses (Paras 10-16)

The Supreme Court accepted the findings that the death was homicidal. Eyewitnesses, including the deceased's mother and local villagers, supported the prosecution’s version of events, substantiating that the appellants had caused the injuries.

Circumstances of the Incident and Absence of Premeditation (Paras 17-20)

The Court noted previous enmity but also considered the likelihood of a sudden altercation over the land issue. The use of agricultural tools (axe, sticks) and absence of premeditation supported the argument for a lesser charge.

Conclusion and Decision (Paras 21-24)

The Supreme Court ruled that the offense fell under Section 304 Part I IPC, not Section 302 IPC, due to the sudden nature of the altercation. The appellants were sentenced to time already served (12 years).

Subjects:

Criminal Appeal – Murder Conviction under Section 302 IPC converted to Section 304 Part I IPC due to sudden quarrel and absence of premeditation.

Criminal Law, Murder, IPC, Sudden Quarrel, Culpable Homicide.