Intent is Crucial in Violent Crimes: Single Blow with Axe Does Not Imply Attempt to Murder," Rules Madhya Pradesh High Court

Conviction under Section 307 IPC altered to Section 326 IPC in light of evidence, leading to reduced sentence for the appellant. In a notable judgment, the High Court of Madhya Pradesh at Indore has modified the conviction of an appellant from attempted murder to causing grievous hurt using a dangerous weapon. The court's decision, delivered by Justice Prem Narayan Singh, emphasizes the necessity of examining the intent and nature of injuries in such cases. This ruling provides significant insights into the judicial approach towards assessing evidence in violent crime cases.

On October 11, 2016, at around 10:00 AM, the complainant, Bagduram, was sitting near his hut situated in his field when the appellant, Meharbansingh, approached him. Meharbansingh insisted that Bagduram remove the soybean hay stored at the boundary between their fields. Bagduram responded that he would remove it once his family members returned. Following this exchange, Meharbansingh assaulted Bagduram with an axe, striking his head and causing severe bleeding. When Meharbansingh attempted to strike again, Bagduram’s son and wife intervened, prompting Meharbansingh to flee, threatening to kill Bagduram. Bagduram was rushed to the hospital by his relatives, and an FIR was registered based on his statement.

Credibility of Witness Testimonies: The court scrutinized the testimonies of 14 prosecution witnesses, including the injured complainant and his relatives. Despite defense arguments labeling these witnesses as biased, the court upheld their credibility. Citing precedents, Justice Singh noted, “A close relative would be the last to screen the real culprit and falsely implicate an innocent person. Their presence at the scene is often a guarantee of truth.”

Medical Evidence and Injury Assessment: The court placed significant weight on the medical reports. Dr. Mahesh Nigwal and Dr. Sushil Kachewar provided crucial evidence, confirming a severe head injury with hemorrhagic contusion and a comminuted fracture. However, the court concluded that the injury, while serious, did not necessarily reflect an intent to kill. Justice Singh remarked, “The injury was grievous but not sufficient to cause death in the ordinary course of nature.”

The court meticulously differentiated between the intent to kill and causing grievous harm. Referencing several Supreme Court judgments, Justice Singh emphasized that a single blow, even to a vital part, does not automatically imply intent to murder. He stated, “The prosecution has not established that the injuries were sufficient to cause death in the ordinary course of nature. The incident occurred during a sudden altercation without premeditation.”

Justice Singh noted, “Injuries caused by the appellant were serious but lacked the lethal intent required for a conviction under Section 307 IPC. The conviction under Section 307 is unsustainable; instead, the appellant is liable under Section 326 IPC for causing grievous hurt.”

The judgment, reducing Meharbansingh’s sentence from seven years to three years, underscores the judiciary's nuanced approach in distinguishing between various degrees of violent offenses. This decision highlights the importance of intent and the nature of injuries in determining the appropriate charges and sentences. The ruling is expected to influence future cases, reinforcing the need for a detailed assessment of evidence and intent in violent crime prosecutions.

Date of Decision: May 2, 2024