Jeyasingh vs. The State
Background
The appellant, Jeyasingh, was a Forester in the Kottagudi Division, Theni District, Tamil Nadu, also holding additional charge of the Mandal Division. On 11th March 2018, a trekking group of 27 people led by the Chennai Trekking Club, and a separate group of 11 people accompanied by a guide sent by the appellant, were both trekking near Kurangani when a sudden forest fire broke out, killing several trekkers who either fell into a ditch while fleeing or died later from burn injuries. The appellant, as accused No. 1, was prosecuted (along with the trek organisers) for offences including culpable homicide not amounting to murder and causing grievous hurt, and sought discharge from the case.
Decision Breakdown
The Supreme Court held that the deaths were caused by a forest fire, which is in the nature of a vis major (an unforeseeable act of nature/force majeure), and that the specific offences invoked, culpable homicide not amounting to murder (requiring knowledge that an act was likely to cause death) and voluntarily causing grievous hurt by dangerous means, could not apply where death resulted from a natural calamity rather than any positive act by the accused. The Court noted it had earlier taken a similar view for a co-accused, finding certain other provisions also inapplicable. It held that both the Sessions Court and the High Court ought to have discharged the appellant instead of requiring him to face trial merely because of his official position as Forester. The Court set aside the orders of both lower courts, discharged the appellant, and allowed the appeal.
Lesson Learnt
Criminal liability for culpable homicide or causing grievous hurt requires that death or injury result from a deliberate or knowing act of the accused: a person cannot be forced to stand trial for deaths caused by a natural disaster like a forest fire merely because of their official role or presence in the area.