Absence of Intention, Sudden Altercation, and Pre-existing Heart Condition: No Case of Murder Made Out: Delhi High Court Acquits Four in Road Rage Death Case

In a strongly worded and meticulously reasoned decision, the Delhi High Court on 9th February 2026 overturned the life sentence of four men convicted in a 2015 road rage death case, holding that the prosecution failed to establish the core ingredients of murder, particularly intention and knowledge of the victim’s medical vulnerability. The Bench of Justice Prathiba M. Singh and Justice Madhu Jain, while allowing four connected criminal appeals, concluded that the case did not fall under Section 302 IPC, and instead modified the conviction to Section 325 IPC (voluntarily causing grievous hurt), ordering the immediate release of the appellants.

“This was not a case of murder — this was a sudden, unfortunate altercation in traffic, worsened by the unknown and severe heart condition of the victim,” the Court observed, setting aside the Sessions Court's conviction that had previously sentenced the men to life imprisonment.

“The Assault Was Spontaneous, The Heart Was Fatally Weak — We Cannot Hold the Accused Liable for What They Couldn’t Have Known”

The Court was hearing four appeals filed by Mohd. Shadab, Mohd. Waseem @ Bhura, Saleemuddin @ Salim, and Mohd. Atif Malik @ Lala, who were convicted by the Sessions Court, Tis Hazari, in September 2025 for allegedly assaulting Shahnawaz, a 50-year-old man who collapsed and died after a brief scuffle near Turkman Gate on the night of 5th April 2015. The quarrel reportedly began after the deceased’s motorcycle slightly touched the appellants’ i20 car.

The trial court had relied heavily on eyewitness accounts from related witnesses, including the deceased’s sons and brothers, and on medical evidence showing head and abdominal injuries. It held that the injuries were sufficient to cause death in the ordinary course of nature and convicted all four under Section 302 read with 34 IPC.

However, the High Court took a sharply different view. “No weapon was used. The assault involved only fist and leg blows. No premeditation or prior enmity has been alleged or proved,” the judges said, highlighting that the incident occurred “in the heat of the moment” and without any intention to cause death.

“The Deceased Was a Cardiac Time Bomb — The Assault May Have Lit the Fuse, But That Alone Doesn’t Make It Murder”

Central to the High Court’s ruling was the medical evidence, which unequivocally recorded that the deceased had a 100% blockage in the right coronary artery, an enlarged heart weighing 400 grams, and prior signs of myocardial infarction.

“The post-mortem clearly records advanced coronary artery disease, with hard, calcified, and gritty arteries. The heart weighed 400 grams — well beyond normal. The risk of sudden cardiac failure in such a person was dangerously high,” the Court noted.

The doctor who conducted the post-mortem, Dr. Jyoti Barwa, testified that the deceased was a high-risk cardiac patient, and while injuries were present, they were not sufficient per se to cause death in the ordinary course of nature. She added, “Even lesser blockage could cause a fatal heart attack. Patients with 100% blockage can survive due to collateral circulation. But such details cannot be determined post-mortem.”

“Section 302 IPC Requires More Than Outcome — It Demands Intention or Knowledge, Both Absent Here”

The Court rejected the prosecution’s reliance on clause ‘thirdly’ of Section 300 IPC, observing that:

“The injuries, though serious, were not inflicted with any knowledge that they were likely to cause death, and certainly not with the intention to kill.”

Referring to the Supreme Court’s decision in Maniklal Sahu v. State of Chhattisgarh, the Bench underscored that causation in cases with multiple contributing factors to death must be carefully analysed. The medical condition of the deceased “could not have been foreseen or known to the accused, and therefore, the requirement of mens rea under Section 302 IPC is not fulfilled,” the Court held.

The Court also found no basis to sustain a conviction under Section 304 IPC, noting that even culpable homicide not amounting to murder requires some degree of intention or knowledge, which was completely absent in the present facts.

“What Remains Is Grievous Hurt, Not Homicide – But the Accused Have Served Three Years Already”

After a detailed re-examination of the injuries, the Court held that the injuries inflicted on Shahnawaz — including blunt force trauma to the head, subarachnoid haemorrhage, and liver laceration — fell under the definition of grievous hurt endangering life under Section 320(8) IPC.

“Internal haemorrhage, liver damage involving 30% of the organ, and cerebral swelling — these are not superficial wounds. These constitute grievous hurt. However, they do not satisfy the threshold of culpable homicide, let alone murder,” the Court ruled.

Accordingly, the conviction was altered to Section 325 IPC read with 34 IPC, which prescribes a maximum sentence of seven years.

The Court took judicial notice of the fact that the appellants had already undergone more than three years of incarceration, ranging from 3 years and 8 months to nearly 4 years, and held:

“They have suffered incarceration proportionate to the gravity of the offence now proven. They are entitled to be released forthwith.”

“Justice Lies Not In the Severity of the Sentence, But In Its Legal Soundness”

Notably, the High Court also cautioned against the over-zealous invocation of murder provisions in incidents that arise suddenly, without pre-planning, and are fuelled by impulsive human emotion.

“The law cannot presume murderous intent from spontaneous acts of aggression, particularly when the medical outcome is shaped significantly by factors unknown to the accused,” the Bench observed.

The Court further held that eyewitnesses who claimed to have arrived at the scene “coincidentally while going to a baraat or party” had dubious credibility and could not be treated as wholly reliable without independent corroboration.

Conviction Reversed, Sentence Modified, Appellants Released

The Court concluded that:

“The conviction under Section 302/34 IPC is unsustainable. The appellants are held guilty under Section 325/34 IPC. Their sentence shall be limited to the period already undergone.”

Accordingly, the appellants — Mohd. Shadab, Mohd. Waseem @ Bhura, Saleemuddin @ Salim, and Mohd. Atif Malik @ Lala — were ordered to be released forthwith, if not required in any other case. Their bail and surety bonds stood discharged.

Date of Decision: 9th February 2026