By No Stretch of Imagination, Can It Be Accepted That the Accused Had the Intention to Cause Death: Supreme Court Modifies Murder Conviction to Culpable Homicide

The Supreme Court revisited the conviction of Kariman under Section 302 of the Indian Penal Code (IPC), modifying it to culpable homicide not amounting to murder under Section 304 Part II, focusing on the assessment of intent and immediate circumstances surrounding the act.

Facts and Issues: Originally convicted for the murder of Dasmet Bai, Kariman’s case was characterized by the alleged use of stones and fists during a sudden quarrel. The critical issue was whether his actions bore the intent necessary for a murder conviction, or if they were more aligned with the definitions under culpable homicide.

Medical Evidence: The Court highlighted that the medical evidence, particularly the single fatal injury observed, did not conclusively establish a natural likelihood of death, questioning the required intent for a murder conviction under Section 302 IPC.

Evaluation of Eyewitness Accounts: Eyewitnesses described the incident as an abrupt altercation, leading the Court to question the premeditation or intention ascribed to Kariman by the lower courts.

Legal Definitions and Intent: Detailed examination of IPC Sections 300 and 304 led the Supreme Court to determine that the facts supported a sudden and impulsive act rather than one with calculated intent to kill, necessitating a downgrade in the severity of the charge.

Sentencing Review: Considering that Kariman had served 17 years, exceeding the typical sentence for the revised charge, the Court adjusted the sentence to time served, directing his immediate release unless detained for other legal reasons.

Decision: The Supreme Court conclusively altered Kariman’s conviction from murder to culpable homicide not amounting to murder and ordered his release based on the time already served, fundamentally changing the legal interpretation of his actions from intentional murder to a less severe culpable act without premeditated intent.

Date of Decision: 22nd April 2024

Kariman v. State of Chhattisgarh