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Ajai Kumar Chauhan v. The State of Uttar Pradesh

Criminal Appeal · 2025 INSC 140Decided 29 Jan 2025
Crl.A. No.-000471-000471 of 2025 (arising from SLP (Crl.) No. 9115 of 2018)
Justice B.R. Gavai · Justice Augustine George Masih · Justice K. Vinod Chandran

Background

In 1985, two young men studying B.Sc. together, who otherwise had a friendly relationship, got into some kind of confrontation at night. The accused called the victim downstairs, and witnesses then heard the victim's cries and found the accused stabbing him. The victim died of his injuries, and the accused was convicted of murder and sentenced to life imprisonment, a conviction upheld by the Allahabad High Court decades later, in 2018.

Decision Breakdown

The Supreme Court found that no witness had actually seen what triggered the assault, no clear motive was established (the prosecution's suggestion of jealousy over a girl was denied by the eyewitnesses), and the two young men were shown to have had cordial relations before the incident. Given this, the Court held it could not be proved that the accused acted with a premeditated intention to kill, and that the incident more likely arose from a sudden fight or provocation. It therefore reduced the conviction from murder (Section 302 IPC) to culpable homicide not amounting to murder under Exception 4 to Section 300 IPC (Part I of Section 304 IPC).

Lesson Learnt

The difference between murder and the lesser offence of culpable homicide often turns on whether the killing was planned or happened in the heat of a sudden quarrel. The law treats an unplanned killing during a sudden fight far more leniently than a premeditated one.

Official source (sci.gov.in)View Judgment (PDF)

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