Court Reduces Murder Conviction to Culpable Homicide and Modifies Sentence to Seven Years

A bench of Justices Sudhanshu Dhulia and K. Vinod Chandran heard an appeal by Ravinder Kumar @ Raju challenging his conviction under Section 302 of the Indian Penal Code and the sentence of life imprisonment. The limited question before the Court, as framed at the admission stage, was whether the offence fell within Section 302 IPC or was to be treated as culpable homicide not amounting to murder under Section 304 IPC, and whether the sentence required modification.

The Court allowed the appeal to the extent of altering the conviction and sentence. It held that the facts did not disclose pre‑meditation or intent to cause death and that the act arose in the course of a group altercation following a hit‑and‑run incident. The conviction under Section 302 was therefore modified to one under Section 304 Part I IPC and the sentence was reduced from life imprisonment to seven years rigorous imprisonment; the fine and default clause were left intact. The Court emphasised the contextual nature of culpability. The Court, in its reasoning, observed: “Definitely, it was in the course of such altercation that the blow was inflicted on the head of the accused resulting in an injury which caused his death. ... There cannot be any intention to cause death alleged but there is definitely an intention to cause bodily injury which resulted in the death. ... the offence has to be found to be one under Section 304 of the I.P.C. being culpable homicide not amounting to murder. However, under Part I of Section 304 of the I.P.C., since the bodily injury deliberately inflicted was likely to cause death and in such circumstance, the conviction has to be modified to be under Section 304 Part I. In the totality of the circumstances based on the evidence led, we are of the opinion that the sentence has to be of 7 years rigorous imprisonment.”

Background

The dispute arose after a three‑wheeler struck a scooter and fled. The scooterist and others, including the deceased and his father, chased and intercepted the offending vehicle. The prosecution alleged that during the ensuing altercation the appellant picked up an iron rod from his vehicle and struck the deceased on the head. A DDR was recorded immediately, but the FIR was lodged only after five days when the injured person died. The post‑mortem recorded a homicidal death attributable to a single head injury. The iron rod was recovered pursuant to the appellant's disclosure under Section 27 of the Evidence Act. At trial the appellant alone was convicted under Section 302 IPC and sentenced to life imprisonment with a fine of Rs.2,000; the two other occupants of the three‑wheeler were acquitted (one acquitted by trial court, another by the appellate court).

This Court confined itself to the nature of the offence and sentencing. Relying on the absence of motive and premeditation, the composition of the parties at the scene, and the testimony describing a heated verbal altercation rather than a pre‑concerted attack, the Court concluded that the act attracted culpability under Section 299 IPC but fell within Exception 1 to Section 300 IPC and thus constituted culpable homicide not amounting to murder. The Court noted that “road rage results in disastrous consequences” and that the assault occurred amid a spontaneous confrontation in which the deceased and his group had confronted the occupants of the vehicle. The Criminal Appeal was allowed to the stated extent; the appellant was directed, if on bail, to surrender within two months before the trial court if he had not already served seven years' imprisonment. Pending applications stood disposed of.

Case Details: Case No.: 2025 INSC 396 Case Title: Ravinder Kumar @ Raju v. State of Punjab Appearances: For the Petitioner(s): [Not indicated in the judgment] For the Respondent(s): [Not indicated in the judgment]