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Maniklal Sahu vs State of Chhattisgarh

Not available · 2025 INSC 1107Decided 12 Sept 2025
Not available
Justice J.B. Pardiwala · Justice R. Mahadevan

Background

The appellant, along with three others, was accused of trespassing into the deceased's house, dragging him to the terrace, throwing him down, and assaulting him with sticks and fists. The victim survived in critical condition for about nine months before dying of septicemia and pneumonia leading to cardio-respiratory arrest. The trial court convicted the appellant and co-accused for murder (Section 302 IPC) and sentenced them to life imprisonment. The High Court of Chhattisgarh partly allowed the appeal, altering the conviction to attempted murder (Section 307 IPC) on the reasoning that the victim did not die directly of the assault injuries but of later medical complications, and reduced the sentence to seven years. The appellant then approached the Supreme Court seeking full acquittal, arguing the long gap between injury and death broke the chain of causation and that eyewitnesses were unreliable.

Decision Breakdown

The Supreme Court examined the law of causation in criminal homicide, holding that if the original injury is of a fatal or life-threatening nature, it makes no difference that death is actually caused by a complication (like septicemia or pneumonia) naturally flowing from that injury rather than the injury itself: the causal connection remains proximate, not remote, merely because of the passage of time. On these facts, the Court found the High Court had committed a serious error in downgrading the offence to Section 307 IPC merely because the victim survived nine months before succumbing to complications arising from the original injuries. However, since the State had not appealed the High Court's order, and the appellant's own appeal only sought a further reduction, the Court found no merit in the appellant's appeal and dismissed it, effectively leaving the Section 307 conviction and seven-year sentence undisturbed as against this appellant.

Lesson Learnt

In law, a person cannot escape a graver criminal charge merely because death was delayed and technically caused by a medical complication. If that complication flows naturally from the original fatal injury, the assailant remains criminally responsible for the death.

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

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