Single fatal blow during sudden altercation without premeditation warrants conviction under Section 304 Part-I IPC.

On September 9, 2019, the deceased, Ramesh Dhruve, was stabbed with a knife near a Ganesh Pandal in Village Kherjhiti

Eyewitnesses (PW-6, PW-11, and PW-12) testified that the appellant, Mukesh Satnami, along with a juvenile co-accused, assaulted the deceased following a prior enmity

The deceased was declared dead at the District Hospital

Dr. Swapnil Tiwari (PW-3) conducted the postmortem, discovering a 14 cm deep stab wound that penetrated the heart, and opined the death was homicidal

Following a memorandum statement by the appellant, the police recovered a knife (Ex. P/1) which the FSL report (Ex. P/39) confirmed bore human blood

The Sessions Judge, Kabirdham, convicted the appellant under Section 302 read with Section 34 of the IPC, sentencing him to life imprisonment

1. Whether the prosecution proved beyond reasonable doubt that the death of Ramesh Dhruve was homicidal in nature?

2. Whether the appellant caused the homicidal death, and if so, whether the conviction under Section 302 of the IPC warrants interference or modification to Section 304?

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

It also applied Section 304 Part-I regarding punishment for culpable homicide when there is knowledge and intent to cause such bodily injury as is likely to cause death

Furthermore, the Court relied on the principles established in Anbazhagan v. The State (2023), which clarified that a single injury can constitute murder unless the facts indicate a lack of premeditation or a sudden quarrel, leading to an inference of guilty knowledge rather than specific intent to murder

The Court affirmed the appellant’s involvement based on consistent eyewitness testimonies (PW-6, PW-11, PW-12) and corroborative medical and forensic evidence showing human blood on the recovered knife

The Court observed that the incident occurred on the "spur of the moment" during an interaction/altercation without evidence of prior concert or premeditation

The Court noted that only a single blow was inflicted, and there was no evidence the appellant acted in a cruel or unusual manner

Applying the Anbazhagan precedent, the Court reasoned that while the appellant possessed the knowledge that a knife blow to the chest was likely to cause death, the lack of premeditation and the presence of a sudden quarrel brought the act under Exception 4 of Section 300

Thus, the intent required for a Section 302 conviction was not established beyond reasonable doubt

It held that while the appellant caused the death, the conviction under Section 302 IPC was unsustainable

The Court set aside the murder conviction and altered it to Section 304 Part-I IPC

Consequently, the sentence of life imprisonment was reduced to 10 years of rigorous imprisonment, while the fine imposed by the trial court remained intact

The appeal was partly allowed