Supreme Court Reduces Murder Conviction to Culpable Homicide in Absence of Premeditation and Motive

"The law does not contemplate stitching the pieces of evidence in a watertight manner. The requirement is proof beyond reasonable doubt—not proof beyond all doubt," observed the Supreme Court while converting a murder conviction under Section 302 IPC to culpable homicide under Section 304 Part I IPC.

Supreme Court of India delivered a significant ruling in a two-decade-old murder case, reducing the conviction of Goverdhan and Rajendra from murder (Section 302 IPC) to culpable homicide not amounting to murder (Section 304 Part I IPC). The appellants, accused of killing their neighbor, Suraj Sharma, with a sharp-edged axe and an iron pipe, were sentenced to the period already served—10 years and 3 months in prison—and fined ₹50,000 each.

The Court emphasized that while the appellants' actions resulted in the victim's death, the absence of motive, premeditation, or intent to kill warranted a reduced conviction. The ruling underscores the judiciary's nuanced approach to distinguishing between murder and culpable homicide under Indian law.

"Absence of Premeditation and Motive Key to Reducing Conviction"

The case stemmed from an incident on September 23, 2001, in a rural area in Chhattisgarh. According to the prosecution, the appellants attacked Suraj Sharma with an axe and iron pipe following a verbal altercation. Suraj sustained multiple injuries, including grievous head wounds, and succumbed to his injuries on September 25, 2001.

The trial court convicted Goverdhan and Rajendra under Section 302 IPC and sentenced them to life imprisonment. The Chhattisgarh High Court upheld the conviction in 2009 while acquitting the third co-accused, Chintaram, the father of the appellants, for lack of sufficient evidence.

The appellants approached the Supreme Court, arguing that they should be acquitted on parity with their father, citing unreliable witness testimony and lack of corroborative evidence.

"Sole Eyewitness Testimony: A Hapless Mother’s Account Withstood Scrutiny"

The prosecution relied primarily on the testimony of Lata Bai (PW-10), the victim's mother, who claimed to have witnessed the assault. Although her statement to the police was recorded after a delay of five days, the Court held that the delay was justified, as she was preoccupied with her son’s treatment. The Court observed:

"Minor discrepancies in a witness’s testimony cannot obliterate the core truth of their account, especially when the testimony resonates with the ring of truth."

Lata Bai testified that she saw Goverdhan and Rajendra striking her son with an axe and pipe, while their father, Chintaram, instigated them. She immediately informed her husband, who sent her to the police station. Her account was corroborated by circumstantial evidence, including the recovery of blood-stained weapons and medical reports linking the injuries to an axe and pipe.

The appellants argued that Lata Bai was an "interested witness" whose testimony should be disregarded. Rejecting this contention, the Court held:
"A close relative is not automatically an interested witness. Ordinarily, a mother would be the last person to falsely implicate innocent individuals for the murder of her own son."

"Reliability of Eyewitness Testimony Undermined by Hostile Witnesses"

Several prosecution witnesses, including neighbors, turned hostile during the trial, claiming ignorance of the incident. The Court observed that these witnesses, who lived in close proximity to the crime scene, provided statements that were "unnatural and evasive," indicating that they had likely been influenced by the acquitted co-accused, Chintaram.

While hostile witnesses did not entirely derail the prosecution’s case, the Supreme Court underscored that the testimony of Lata Bai was consistent and corroborated by medical evidence. The Court remarked:
"The testimony of a sole eyewitness, if trustworthy and corroborated by medical or circumstantial evidence, is sufficient to sustain a conviction."

"Lack of Intention to Kill Warrants Lesser Conviction"

A pivotal aspect of the judgment was the absence of clear motive or premeditation. The Court noted that neither the prosecution nor the eyewitness established a specific reason for the attack. Furthermore, the deceased succumbed to his injuries three days after the assault, which the Court found indicative of a lack of intent to kill.

The Court observed:
"The circumstances do not demonstrate premeditation or clear intent to kill. While the appellants knew that their actions could cause death, this knowledge alone does not elevate their conduct to murder."

Consequently, the Court held that the appellants were guilty of culpable homicide not amounting to murder under Section 304 Part I IPC.

The Supreme Court sentenced the appellants to the period they had already served—10 years and 3 months in prison—and imposed a fine of ₹50,000 each, payable to the victim's family. The Court reasoned that this punishment was proportionate to the nature of the crime and the time already spent in incarceration. It also clarified that the acquittal of the third accused, Chintaram, did not warrant parity for the appellants, as there was stronger evidence against them.

This ruling highlights the judiciary’s meticulous examination of evidence and its commitment to ensuring proportionate justice. By reducing the conviction from murder to culpable homicide, the Supreme Court reaffirmed the principle that criminal liability must align with the intent, motive, and circumstances surrounding an offense.

Date of Decision: January 9, 2025