Supreme Court: Murder Conviction Converted to Culpable Homicide under Section 304 Part I IPC.

Headnote:

The Supreme Court converted the conviction of the appellant from Section 302 IPC (murder) to Section 304 Part I IPC (culpable homicide not amounting to murder). The Court held that although the accused knowingly inflicted fatal injuries with a knife, there was no premeditation or clear intention to cause death. The incident occurred in a sudden fit of anger following a quarrel, and the victim’s death after 13 days due to septicemia indicated the absence of deliberate intent to kill.

Background:

1. The appellant was convicted by the City Sessions Court, Ahmedabad, for offences under Sections 302 and 504 IPC for fatally stabbing Louis Williams on 13 June 1998.
2. The High Court of Gujarat affirmed the conviction and life sentence.
3. The incident stemmed from a prior quarrel involving the deceased’s nephew, Rajesh. Later that night, the appellant entered the deceased’s house, abused him, and inflicted knife injuries on his abdomen and hand.
4. The victim was hospitalized, underwent surgery, and died on 26 June 1998 from septicemia.

Court’s Observations:

1. The Supreme Court reviewed the evidence of eyewitnesses Gajraben (sister of the deceased) and Rajesh (nephew), and medical testimony from Dr. Dharmila Shah (PW 8).
2. It was observed that the accused inflicted serious injuries knowingly but without premeditated intent to cause death.
3. The Court applied principles from Kesar Singh v. State of Haryana (2008) 15 SCC 753 and Virsa Singh v. State of Punjab (AIR 1958 SC 465), emphasizing that intention distinguishes murder from culpable homicide.
4. The act was impulsive, arising from self-provocation and anger, thus not constituting murder under Section 300 IPC.
5. Death resulted from septicemia after 13 days, not from instantaneous fatality, further supporting reduction of the offence.

Decision:

1. Conviction under Section 302 IPC was set aside and replaced with conviction under Section 304 Part I IPC.
2. The Court noted that the appellant had already served over 14 years in jail; hence, the sentence was deemed sufficient.
3. The appeal was allowed, and the appellant’s bail bond was discharged.

Legal Provisions Discussed:

1. Sections 299, 300, 302, 304 (Part I & II), and 504 – Indian Penal Code, 1860
2. Section 313 – Code of Criminal Procedure, 1973

Citation: 2025 INSC 1302

Case: Nandkumar @ Nandu Manilal Mudaliar v. State of Gujarat

Court: Supreme Court of India

Date of Decision: 10 November 2025

Criminal Appeal No.: 1266 of 2014