A single fatal blow to a vital organ following a quarrel constitutes murder under Section 302 IPC.

The appellant and the deceased were police colleagues stationed at 12th APBN Camp and on the night of 27/09/2017, they engaged in a quarrel while playing cards.

The Platoon Commander (PW-1) intervened at approximately 10:30 p.m. and ordered both to their respective beds.

At roughly 1:30 a.m. on 28/09/2017, witnesses heard the deceased scream "I am dying".

Witnesses saw the appellant standing near the deceased's bed, where the deceased lay with a fatal stab wound to the left chest.

The appellant allegedly expressed regret, stating he did not intend to kill the deceased.

A blood-stained knife was recovered the following morning.

The Trial Court convicted the appellant under Section 302 IPC. The appellant appealed, claiming the act fell under Exception 4 to Section 300 IPC (sudden fight).

1. Whether the prosecution proved beyond reasonable doubt that the appellant caused the death of the deceased.

2. Whether the act of the appellant is covered under Exception 4 to Section 300 IPC, thereby reducing the offense to Section 304 Part-II IPC.

Section 300 (Clause Thirdly) and Section 302 of the IPC regarding murder.

Exception 4 to Section 300 IPC, which requires that culpable homicide be committed without premeditation in a sudden fight in the heat of passion upon a sudden quarrel.

The court relied on Ghapoo Yadav v. State of M.P. to define the four necessary conditions for Exception 4.

The court relied on Pulicherla Nagaraju v. State of A.P. to determine "intention" based on the nature of the weapon, the vital part of the body targeted, and the force used.

The court cited Jagrup Singh v. State of Haryana to establish that a solitary blow to a vital part can constitute murder depending on the attendant circumstances.

The court rejected the appellant's plea for Exception 4, noting that while there was a "quarrel," there was no evidence of a "sudden fight".

The court observed that the initial quarrel ended at 10:30 p.m., providing a three-hour "cooling period" before the fatal incident at 1:30 a.m.

The court found that the appellant used a dangerous weapon (knife) to strike a vital part of the body (chest) while the deceased was likely vulnerable or asleep.

This conduct, coupled with the appellant’s presence at the bedside and subsequent admissions of "mistake," established the requisite intention under Clause Thirdly of Section 300.

The court highlighted that because the deceased was unarmed and no mutual combat occurred, the appellant took undue advantage, disqualifying him from the benefit of Exception 4.

The court concluded that the act amounted to culpable homicide amounting to murder as the ingredients of Section 300 Clause Thirdly were satisfied and no exceptions applied; the appeal was dismissed, and the conviction and sentence passed by the Sessions Judge, Udalguri, were upheld.