Supreme Court holds injuries and their complications were proximate cause of death; finds High Court erred in treating case as Section 307 but dismisses convict's appeal

A bench of Justices J.B. Pardiwala and R. Mahadevan heard the criminal appeal filed by the convict, Maniklal Sahu, against the High Court of Chhattisgarh’s order which partly allowed his criminal appeal and altered his conviction under Section 302 IPC to one under Section 307 IPC. The appeal raised the question whether the long interval of about nine months between the assault and the death of the injured man broke the chain of causation and negated a charge of murder.

The Court summarised that the medical and ocular evidence established that the deceased ultimately died of septic shock with bilateral pneumonia arising from post‑traumatic spinal cord injury with paraplegia and infected bedsores, and that those consequences flowed from the injuries sustained in the assault. The Court found that the High Court erred in concluding that the lapse of time and alleged deficiencies in treatment converted the offence into an attempt to murder under Section 307. The Court emphasised the legal principle governing causation and delayed deaths, noting that a supervening complication did not necessarily break causation where it was the natural or probable consequence of the original injury. The Court, in its reasoning, observed: "To sum it up, where death is delayed due to later complications or developments, the courts should consider the nature of the injury, complications or the attending circumstances. If the complications or developments are the natural, or probable, or necessary consequence of the injury, and if it is reasonably contemplated as its result, the injury could be said to have caused death. If on the other hand, the chain of consequences is broken, or if there is unexpected complication causing new mischief, the relation of cause and effect is not established, or the causal connection is too remote then the injury cannot be said to have caused death. If the original injury itself is of a fatal nature, it makes no difference that death is actually caused by a complication naturally flowing from the injury and not the injury itself, since causal connection is proximate." The Court also recorded that "there had been no such considerable change of circumstances as to snap the chain of causation."

Background The prosecution case was that on 22 February 2022 the appellant and three others trespassed into the deceased Rekhchand Verma’s house, dragged him to the terrace, threw him down and thereafter assaulted him with sticks and fists. The injured was treated at multiple centres and survived in a disabled, bedridden condition for about nine months before he died on 8 November 2022. Dying declarations and eyewitness testimony of family members named the appellant; three doctors who treated or examined the patient gave unchallenged evidence that the injuries included a serious head wound and post‑traumatic spinal cord injury leading to paraplegia, infected bedsores, pneumonia and septic shock. The Sessions Court convicted the accused for murder under Section 302 IPC and sentenced them to life imprisonment. The High Court partly allowed criminal appeals and altered the conviction to Section 307 IPC, sentencing the accused to seven years’ rigorous imprisonment and a fine, on the view that the death followed after a long interval and, in the High Court’s assessment, owing to lack of proper treatment.

The Supreme Court examined statutory provisions, precedent and medical evidence, including Explanation 2 to Section 299 IPC and authorities on causation in delayed deaths. The Court reviewed authorities holding that death resulting from complications which were the natural and probable consequences of the injury remained legally attributable to the assailant and that evidence of possible effective medical treatment was irrelevant to negate causation under Explanation 2. The Court concluded that the injuries were sufficient in the ordinary course of nature to cause death and that the supervening septic complications were a proximate consequence of the assault. While the Court held the High Court was wrong to characterise the offence as an attempt to murder under Section 307 on the ground of lapse of time or alleged inadequate treatment, the Court recorded the procedural posture that no acquittal or enhancement appeal lay by the State and, ultimately, disposed of the instant appeal by observing that "there is no merit in the appeal" and dismissing it.

Case Details: Case No.: CRIMINAL APPEAL NO. 5578 OF 2024 Case Title: MANIKLAL SAHU …APPELLANT VERSUS STATE OF CHHATTISGARH …RESPONDENT Appearances: For the Petitioner(s): [Names not specified in the extract] For the Respondent(s): [Names not specified in the extract]