Culpable Homicide Modified to Section 304 Part II IPC for Deaths Arising From Sudden Domestic Quarrels Without Premeditation

The Appellants were convicted by the Trial Court under Sections 302/34 (Murder) and 323/34 (Voluntary causing hurt) of the IPC for an incident occurring on the night of June 21, 2019

It was alleged that during a sudden domestic quarrel at the deceased’s house, the Appellants assaulted Amartiya Bai and her husband, Ramprasad (PW-12), with bamboo sticks

Amartiya Bai died on the spot due to shock and hemorrhage from a head injury

The Appellants challenged the conviction, contending that the act occurred during a sudden fight without premeditation or lethal weapons, and thus did not amount to murder

1. Whether the death of the deceased was homicidal in nature

2. Whether the Appellants were the perpetrators of the crime

3. Whether the act of the Appellants constitutes murder under Section 302 IPC or culpable homicide not amounting to murder under Exception 4 to Section 300 IPC

The Court applied Section 300 IPC, specifically Exception 4, which reduces murder to culpable homicide not amounting to murder if the act is committed without premeditation in a sudden fight in the heat of passion

It relied on Sukhbir Singh v. State of Haryana [(2002) 3 SCC 327] regarding the lack of common object and sudden passion

Gurmukh Singh v. State of Haryana [(2009) 15 SCC 635] for factors determining the nature of the offense such as weapon type and health of the accused

Arjun v. State of Chhattisgarh [(2017) 3 SCC 247], which clarifies that "knowledge" of the likelihood of death without "intention" to kill attracts Section 304 Part II IPC

The Court confirmed the death was homicidal based on the postmortem report (Ex. P-14) and testimony of Dr. K.K. Dhruv (PW-7)

While the participation of the Appellants was proven through the testimony of the injured eyewitness (PW-12) and the recovery of blood-stained bamboo sticks confirmed via FSL report (Ex. P-31), the Court found that the prosecution failed to prove "intention" to murder.

The Court reasoned that the incident was a spontaneous domestic altercation occurring without premeditation

The use of common bamboo sticks instead of lethal weapons and the absence of prior enmity indicated that the Appellants did not intend to cause death

Applying the four-pronged test from Rambir v. State (NCT of Delhi), the Court held that the Appellants possessed "knowledge" that their blows were likely to cause death but lacked specific "intent," thus satisfying Exception 4 to Section 300 IPC

The High Court set aside the conviction under Section 302/34 IPC and modified it to Section 304 Part II IPC; the Appellants were sentenced to seven years of rigorous imprisonment

Appellant No. 2's bail bonds were cancelled, and he was ordered to surrender within four weeks to serve the remainder of the modified sentence