Absence of Causal Link Between Alleged Assault and Death Vitiates Charge of Murder Under Section 103 BNS.

The petitioners sought quashment of FIR Crime No. 189/2025 registered at P.S. Thatipur for offences under Sections 103 (Murder) and 3(5) (Joint Liability) of the Bharatiya Nyaya Sanhita (BNS), and Section 3(2)(v) of the SC/ST Act.

The prosecution alleged that on April 25, 2025, the petitioners assaulted the deceased, Anil Mahaur, with an iron rod, kicks, and punches during a street quarrel.

The deceased died later that day.

However, the post-mortem report attributed the cause of death to cardio-respiratory failure (heart failure/heat shock) rather than external injuries.

CCTV footage showed a scuffle but did not prima facie indicate a fatal assault.

Whether the material on record, specifically the medical evidence and CCTV footage, prima facie establishes the ingredients of murder under Section 103 of the BNS.

Whether the continuation of criminal proceedings under Section 103 of the BNS constitutes an abuse of the process of law when medical evidence rules out the assault as the cause of death.

The court primarily applied Section 103 of the Bharatiya Nyaya Sanhita (BNS), which defines murder and requires proof of intention or knowledge that the act would cause death.

It also exercised inherent powers under Section 482 of the Code of Criminal Procedure (CrPC) to prevent abuse of the court's process and secure the ends of justice.

The court noted that while exercising Section 482 jurisdiction, it does not typically conduct a detailed appreciation of evidence but must ensure the ingredients of the alleged offence are prima facie satisfied.

The court examined the discrepancy between the ocular testimony and the medical evidence.

While witnesses claimed a brutal assault with an iron rod caused the death, the post-mortem report categorically stated the cause of death was cardio-respiratory failure due to "heart fail," with no link to external injuries.

The court reasoned that for a charge under Section 103 of the BNS to stand, there must be a direct causal connection between the accused's acts and the victim's death.

Upon reviewing the CCTV footage, the court found evidence of a physical altercation but concluded it lacked the nature of a murderous assault.

Consequently, the court found that while a physical scuffle occurred, the specific charge of murder was not supported by the medical record.

It set aside the FIR specifically regarding the offence under Section 103 of the BNS.

However, acknowledging that an altercation did occur, the Court directed the investigating agency to conduct a "further/fresh investigation" to determine the exact nature of the incident and file a fresh charge-sheet for any other appropriate offences disclosed by the material.

The investigating agency was ordered to proceed independently without being influenced by the court’s observations on merits.