Supreme Court Upheld Conversion of Murder Conviction to Culpable Homicide Not Amounting to Murder

Supreme Court dismissed the State of Madhya Pradesh's appeal preferred against the High Court of Madhya Pradesh, Jabalpur's judgment which had partially reversed the conviction of Shyamlal and other respondents. The Convicts/Respondents were first convicted by the Trial Court under Sections 147, 452, 302, 325, and 323 read with Section 149 of the Indian Penal Code, 1860 (IPC) and were mainly convicted of murder for which they were given life imprisonment.

Background:
The case stemmed from an attack on November 1, 1989, in which the respondents, said to have been acting with a common intention, attacked various persons including the late Laxman, based on a belief that PW-1 had injured their buffalo. The prosecution argued that the respondents had first attacked certain persons in a field and subsequently went on to attack others, including pulling out the deceased from his residence.

The High Court of Madhya Pradesh modified the Trial Court's judgment. While confirming the conviction for other offences, the High Court set aside the conviction under Section 302 read with Section 149 of the IPC, converting it to a conviction under the second part of Section 304 of the IPC (culpable homicide not amounting to murder).

The High Court considered the incident's age (1989) and the advanced age of the respondents, with the first respondent being nearly eighty and four others over seventy. Ultimately, the High Court let off the respondents with the sentence already undergone (seventy-six days) and imposed a fine of Rs. 16,000 each, directing a portion of it as compensation to the family of the deceased and some injured witnesses. The High Court relied on the simple nature of the injuries inflicted on the deceased as per the medical report and the inconclusive cause of death mentioned in the post-mortem notes (asphyxia with no discernible cause and no detection of poison) to conclude there was no intention to commit murder.

Arguing the unjustifiablity of the High Court's Judgment the appeal was preferred. However, the Supreme Court, after examining the evidence, particularly the medical evidence, found no reason to interfere with the High Court's judgment. The Supreme Court highlighted the statement of PW-17 (Dr. Baburam Arya), who examined the deceased, noting that while the injuries were before death, the cause of death was attributed to suffocation with no definite reason provided. The post-mortem report also did not conclusively link the inflicted injuries to the death, which occurred fifteen days after the incident. The Court observed that the medical evidence created a serious doubt about whether the respondents' actions directly caused Laxman's death, even raising questions about the applicability of Section 304 of the IPC.

Furthermore, the Supreme Court took into account the significant lapse of time since the incident (almost thirty-six years by the time the Supreme Court delivered its judgment in 2025) and the advanced age of the accused and took into consideration the fine imposed by the High Court.

Ultimately, the Supreme Court dismissed the State's appeal, upholding the High Court's decision to let off the respondents on the sentence already undergone. The Supreme Court also made a postscript observation about the huge pendency of old criminal appeals in High Courts and suggested that a balance needs to be struck to prioritize even appeals where accused are on bail, especially considering the long lapse of time and the age of the appellants.

Coram: Justice Abhay S Oka, Justice Ahsanuddin Amanullah, and Justice Augustine George Masih
Between: State of Madhya Pradesh Vs Shyamlal & Ors. 2025 INSC 377
Date of Judgment: 20-03-2025