The Supreme Court on Wednesday sharply criticized the Chhattisgarh High Court for what it described as a “pathetic condition” and a misapplication of basic criminal law. A Supreme Court Bench, comprising Justice J.B. Pardiwala and Justice K. Vinod Chandran, expressed dismay over the High Court’s decision to reduce a murder conviction to culpable homicide not amounting to murder.
The Supreme Court was hearing a challenge to the Chhattisgarh High Court’s November 2024 judgment. This judgment had altered an accused’s conviction from Section 302 of the Indian Penal Code (IPC), which deals with murder, to Section 304 Part II IPC, pertaining to culpable homicide not amounting to murder. Consequently, the sentence was reduced from life imprisonment to 10 years.
“Just see the pathetic condition of the High Court. The judges don’t know what is Section 304 Part I and Section 304 Part II of the IPC! And you expect the judges to appreciate the evidence!” the Bench remarked. The Supreme Court noted that such fundamental principles are typically taught in the first year of law school.
The case involves the death of a woman who was assaulted in February 2021. The prosecution stated that the accused visited the woman’s home seeking her son. The woman was later found deceased, and according to her husband, she identified the accused as her assailant before her death. A post-mortem examination revealed head and face injuries, attributing her death to a head injury.
In September 2022, a trial court convicted the accused of murder under Section 302 IPC and imposed a life sentence. However, the Chhattisgarh High Court, in November 2024, reasoned that the assault occurred during a sudden quarrel and that the accused lacked the intention to kill the woman. This led to the conviction being altered to Section 304 Part II IPC.
Distinguishing Between Culpable Homicide Provisions
The Supreme Court highlighted the critical distinction between Section 304 Part I and Part II of the IPC. Section 304 Part I applies when an act is committed with the intention of causing death or bodily injury likely to cause death. Section 304 Part II, conversely, applies when the accused has knowledge that their act is likely to cause death, but without the specific intention required for Part I.
The Supreme Court found that the High Court had altered the conviction in a “slipshod manner.” The Bench observed that the High Court appeared to have overlooked the nature of the injuries, the weapons used, and the circumstances surrounding the incident. The Court stated, “The High Court as usual in a very slipshod manner and without any understanding of law partly allowed the appeal by altering the conviction from Section 302 to Section 304 Part II of IPC.”
In response to these concerns, the Supreme Court issued a notice. The notice calls upon the accused to explain why the High Court’s judgment should not be overturned and the original murder conviction by the trial court reinstated. The Supreme Court indicated it would review the matter on its merits after considering the relevant circumstances. The State of Chhattisgarh has also been asked to provide a response.
This proceeding will determine the validity of the Chhattisgarh High Court’s decision to reduce the murder conviction. The case underscores the importance of precise application of criminal law principles, particularly concerning intent and knowledge in homicide cases. This situation arises as the Supreme Court often addresses splits among lower courts on criminal law interpretations.
The wider legal community is increasingly focused on judicial training and the consistent application of legal precedents. Recent discussions in the legal industry highlight trust and equity concerns amidst innovation, and the need for robust understanding of fundamental legal concepts across all levels of the judiciary.
