Supreme Court bench, comprising Justices B R Gavai and P S Narasimha, critically evaluated the evidence and testimonies that had led to the conviction of the man
The Supreme Court of India has significantly altered the course of a conviction in a murder case, offering a fresh perspective on the distinction between murder and culpable homicide. The apex court’s decision came as a beacon of hope for one of the four individuals previously sentenced to life imprisonment, as his sentence was reduced to a ten-year jail term. This decision was rooted in a meticulous examination of his involvement in the crime, which led to a reclassification from murder to culpable homicide.
The bench, comprising Justices B R Gavai and P S Narasimha, critically evaluated the evidence and testimonies that had led to the conviction of the man, referred to as accused number 3 (A3), by both a trial court and the Telangana High Court. The Supreme Court found that the lower courts had “mechanically drawn an inference” against A3, primarily based on his proximity to the crime scene and his familial ties with the other accused, without a deeper analysis of his actual intent and participation in the crime.
“In fact, both the courts have mechanically drawn an inference against A3 under section 34 of the Act merely based on his presence near the scene of offence and his familial relations with the other accused,”
the bench stated, highlighting a critical oversight in the judicial process that led to the reevaluation of A3’s conviction.
Upon a thorough review of the eyewitness statements and the post-mortem report, the Supreme Court concluded that it was untenable to assert that A3 harbored any intention to murder the deceased. This conclusion was drawn from a detailed analysis of the circumstances surrounding the crime, notably A3’s actions during the incident. Unlike the other accused, A3 never wielded the axe, a key weapon in the assault, nor did he engage in the physical attack on the victim.
“The cumulative circumstances in which A3 was seen participating in the crime would clearly indicate that he had no intention to commit murder of the deceased for two clear reasons. Firstly, while every other accused took the axe used by A1 initially and contributed to the assault with this weapon, A3 did not wield the axe at any point of time. Secondly, A3 only had a stone in his hand and, in fact, some of the witnesses said he merely threatened in case they seek to intervene and prevent the assault,”
the justices elaborated, delineating the rationale behind their verdict.
This nuanced understanding of A3’s participation led the Supreme Court to acquit him of the charge under section 302 read with section 34 of the Indian Penal Code (IPC), which pertains to murder committed with a common intention. Instead, the court found A3 culpable under section 304 Part II of the IPC, recognizing his involvement in the crime without the intent to kill, thus commuting his sentence to ten years.
“Even though A3 might not have had the common intention to commit the murder, nevertheless, his participation in the assault and the wielding of the stone certainly makes him culpable for the offence that he has committed. While we acquit A3 of the offence under section 302 read with section 34 of the IPC, he is liable for the offence under 304 Part II IPC,”
the bench concluded, marking a significant moment in the interpretation of criminal intent and participation in the Indian legal system.
This ruling not only sheds light on the complexities of legal definitions of murder versus culpable homicide but also emphasizes the importance of a detailed and nuanced examination of each accused’s role in a crime. It serves as a reminder of the judiciary’s role in ensuring that justice is served accurately, taking into account the specifics of each case.
