Medical Evidence Does Not Prove That Injuries Caused Death: Supreme Court Refuses to Restore Murder Conviction

"Laxman Had Died Due to Suffocation. It Was Difficult to Give a Definite Reason" _- Supreme Court of India delivered a significant judgment in State of Madhya Pradesh vs. Shyamlal & Ors., refusing to restore the murder conviction under Section 302 IPC which had been set aside by the Madhya Pradesh High Court. The Court dismissed the State's appeal, observing that the medical evidence failed to establish a clear link between the injuries inflicted and the death of the victim, and upheld the High Court’s decision to convict the accused under Section 304 Part II IPC, sentencing them to the period already undergone.

"Only Because Death Occurred Fifteen Days Later, It Cannot Be Presumed That Section 302 IPC Is Inapplicable" – State's Argument Rejected
The case arose from a violent assault that took place on 1st November 1989, in which the accused allegedly formed an unlawful assembly and attacked several persons, including Laxman (deceased), using ballams (spears) and sticks, due to a dispute involving the cutting of a buffalo's tail. The Trial Court convicted the accused under Sections 147, 452, 302, 325, and 323 read with Section 149 IPC and sentenced them to life imprisonment under Section 302/149 IPC.

The High Court, however, in its judgment dated 24th August 2017, held that the offence did not fall under Section 302 IPC, but under the second part of Section 304 IPC, as the intention to kill was not established, especially considering the medical cause of death remained indeterminate.

“Laxman Had the Following Injuries…” – Court Reproduces Medical Evidence to Emphasize That Wounds Were Not Sufficient to Cause Death
The prosecution relied on the testimony of PW-17, Dr. Baburam Arya, who had examined Laxman and other injured persons. According to Dr. Arya: “Laxman had the following injuries on his body: lacerated wounds on the skull, elbow, forearm, eyebrow, and nose, as well as swelling and superficial scratches.”

However, Dr. Arya further stated: “All the injuries were before death. Laxman had died due to suffocation. It was difficult to give a definite reason.”

The post-mortem report recorded “asphyxia” as the cause of death but added that the exact cause could not be ascertained, leading to viscera being preserved for chemical examination, which ruled out poisoning.

Referring to this, the Supreme Court remarked: “Neither the cause of death mentioned in the post-mortem report nor the evidence of PW-17 prove that the injuries inflicted upon the deceased resulted in his death.”

The Court noted that Laxman died fifteen days after the incident, and the lack of direct medical correlation between the injuries and the death introduced serious doubt over the applicability of Section 302 IPC.

“Even Section 304 IPC Is in Serious Doubt” – Supreme Court Refuses to Interfere, Citing Long Delay and Age of Accused
The Court observed: “There is a serious doubt whether even Section 304 of the IPC could have been applied, as the medical opinion does not support the theory of homicidal death of the deceased.”

It also considered the fact that at the time of the High Court judgment, four accused were above 70 and one was nearly 80 years old, and that 28 years had passed since the incident, making it inappropriate to send them back to jail.

“A substantial amount of Rs.16,000/- each has been imposed by the High Court by way of fine. Therefore, it will not be appropriate to interfere with the impugned judgment of the High Court.”

“If Appeals Are Heard After Decades, The Question Arises Whether Accused Should Be Sent Back To Jail” – Supreme Court’s Post-Script on Judicial Delays
In an important post-script, the Court highlighted the issue of delay in disposal of criminal appeals, especially when the accused are out on bail.

“It is desirable that certain categories of appeals against conviction where the accused are on bail should be given priority.”

The Court warned that hearing appeals decades later leads to complications, particularly in sentencing, as it may be unjust to send aged accused back to jail after a long gap.

The Supreme Court ultimately found no merit in the State’s appeal to restore the murder conviction under Section 302 IPC, upholding the High Court's decision to convict under Section 304 Part II. Emphasizing the lack of definitive medical evidence, the age of the accused, and long passage of time, the Court applied a humane approach, reinforcing the importance of balanced sentencing in the criminal justice system.

Date of Decision: March 20, 2025