The Supreme Court dismissed the appeal of Kunhimuhammed @ Kunheethu challenging his conviction and life sentence for murder under Section 302 IPC. The Court held that the fatal stabbing of the deceased during a politically charged altercation constituted murder, as the appellant intended to cause injuries sufficient in the ordinary course of nature to result in death. The Court also rejected the appellant's arguments for reducing the sentence on grounds of self-defense, lack of premeditation, old age, and medical condition.

Acts and Sections Discussed:

1. Indian Penal Code, 1860
   • Section 302 (Murder)
   • Section 326 (Voluntarily causing grievous hurt by dangerous weapons)
   • Section 324 (Voluntarily causing hurt by dangerous weapons)
   • Section 34 (Acts done by several persons in furtherance of common intention)
2. Indian Evidence Act, 1872
   • Section 27 (Discovery of facts through confessions)
3. Code of Criminal Procedure, 1973
   • Section 313 (Examination of the accused)

Background Facts

1. Incident (Paras 2.1–2.3):
   A political altercation between rival factions (United Democratic Front and Left Democratic Front) led to an ambush at Mukkilaplavu Junction. The appellant stabbed the deceased multiple times with a knife after an initial scuffle involving tamarind sticks. The co-accused also inflicted injuries on the victims.

2. Investigation (Para 2.4):
   Police registered an FIR under Sections 302/324 read with Section 34 IPC. The murder weapon (knife) was recovered based on the appellant's disclosure statement.

3. Trial (Paras 3–5):
   The Trial Court convicted the appellant under Sections 302, 326, and 324 IPC, sentencing him to life imprisonment and fines. The conviction was based on eyewitness testimony, medical evidence, and forensic findings.

Findings of the Trial Court

4. Role of Evidence (Paras 10–15):

   • Eyewitness PW-1, an injured victim, provided consistent testimony about the appellant’s actions.
   • Medical reports confirmed the fatal nature of the stab wounds.
   • Recovery of the blood-stained knife matched the deceased’s blood group, corroborating the prosecution's case.

5. Rejection of Private Defense (Para 14):
   The appellant’s injuries were minor, disproving his claim of imminent danger or lawful private defense.

6. Conviction (Para 15):
   The appellant was found guilty of murder under Section 302 IPC. Co-accused were convicted under Section 326 IPC for grievous hurt but acquitted of murder due to lack of common intention.

Findings of the High Court

7. Reaffirmation of Conviction (Paras 16–24):
   • The High Court upheld the Trial Court’s findings, emphasizing the intent to kill based on the deliberate targeting of vital organs.
   • Co-accused were deemed less culpable, lacking prior knowledge of the appellant’s possession of the knife.

Supreme Court Analysis

8. Rejection of Arguments for Reduction of Sentence (Paras 25–30):

   • Lack of Premeditation: The spontaneous nature of the altercation does not negate intent, as intent can form during the act.
   • Private Defense: The appellant’s minor injuries did not justify the disproportionate force used.
   • Parity with Co-accused: The appellant’s actions were distinct and more culpable than those of his co-accused.
   • Old Age and Health: The seriousness of the crime outweighs personal circumstances.

9. Legal Principles Cited (Paras 25.4–25.12):

   • Virsa Singh v. State of Pepsu (1958 SCR 1495): Intent to inflict fatal injuries sufficient in the ordinary course of nature qualifies as murder.
   • Balkar Singh v. State of Uttarakhand (2009) 15 SCC 366: Liability arises if the injury is sufficient to cause death in the ordinary course.

10. Final Verdict (Para 31):
    The appeal was dismissed. The conviction and life sentence were upheld.

Ratio Decidendi:

The deliberate infliction of fatal injuries using a sharp weapon during a politically motivated altercation, targeting vital organs with knowledge of likely death, constitutes murder under Section 300 IPC. The lack of premeditation or spontaneous escalation does not absolve intent formed during the act.

Subjects: Criminal Law

• Keywords: Murder, Political Rivalry, Intent, Private Defense, Indian Penal Code, Section 302 IPC
• Legal Concepts: Culpable Homicide, Mens Rea, Eyewitness Testimony, Forensic Evidence, Sentence Reduction