Conviction modified to Section 304 Part-I for sudden assault without premeditation in heat of passion.

On December 30, 2020, the deceased, Munia Yadav, was fetching water when the appellant (her daughter-in-law) struck her on the head with a stone and an axe, resulting in fatal head injuries

Eyewitness accounts from the deceased’s husband (PW-1) and son (PW-2) confirmed the assault

The appellant was convicted by the Trial Court for murder under Section 302 IPC, concealment of evidence under Section 201 IPC, and Sections 4 & 5 of the Chhattisgarh Tonahi Pratadna Nivaran Adhiniyam, 2005 (dealing with witchcraft-related harassment), and was sentenced to life imprisonment

The appellant challenged this, contending that the act was committed in a sudden heat of passion without premeditation

1. Whether the death of Munia Yadav was homicidal in nature

2. Whether the appellant was the perpetrator of the crime

3. Whether the act of the appellant falls under Exception 4 to Section 300 IPC, warranting a conversion of the conviction from Section 302 IPC to Section 304 IPC

The court primarily applied the distinction between murder (Section 302 IPC) and culpable homicide not amounting to murder (Section 304 IPC).

It relied on Exception 4 to Section 300 IPC, which mitigates murder to culpable homicide if the act is committed without premeditation in a sudden fight in the heat of passion

The court cited Basdev v. State of Pepsu regarding the distinction between 'intent' and 'knowledge'

The court relied on Gurmukh Singh v. State of Haryana, which provided a multi-factor test for sentencing, including the nature of the weapon, the lack of previous enmity, and the spur-of-the-moment nature of the incident

It further applied the four-ingredient test for Exception 4 established in Arjun v. State of Chhattisgarh and Rambir v. State (NCT of Delhi)

The court affirmed the Trial Court's finding that the death was homicidal based on medical evidence (PW-8) showing a depressed fracture of the temporal bone

The Court confirmed the appellant’s identity through the consistent eyewitness testimonies of PW-1 and PW-2

Regarding the nature of the offense, the Court observed that there was no evidence of premeditation or motive

The assault occurred "all of a sudden" and out of anger

The court reasoned that the appellant satisfied the four requirements of Exception 4 to Section 300: (i) it was a sudden fight, (ii) there was no premeditation, (iii) the act was done in the heat of passion, and (iv) the assailant did not act in an unusually cruel manner

Consequently, the court found that while the appellant had the requisite "guilty knowledge and intention" that the injuries were likely to cause death, the lack of premeditation moved the offense into the realm of Section 304 Part-I IPC

The appellant was sentenced to 10 years of Rigorous Imprisonment (RI)

The convictions and sentences under Section 201 IPC and Sections 4 & 5 of the Adhiniyam, 2005, were affirmed

The appellant was ordered to serve the remaining sentence as modified