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Maukam Singh v. The State of Madhya Pradesh

Criminal Appeal · 2025 INSC 435Decided 2 Apr 2025
Crl.A. No.-001741-001741 - 2025 (@ SLP (Crl) No.13369 of 2024)
Justice Sudhanshu Dhulia · Justice K. Vinod Chandran

Background

A dispute arose after one of the victims' family members worshipped a deity installed on a piece of disputed land. Angered by this, several accused, instigated by the person occupying the land, went armed to the house of the family and a scuffle broke out, in which the elderly grandfather died from a head injury and his three grandchildren were injured. The trial court convicted three of the accused under Section 302 (murder) read with Section 34 IPC (common intention) and sentenced them to life imprisonment, along with lesser sentences for the injuries to the grandchildren; the High Court affirmed this conviction, and the accused appealed to the Supreme Court arguing the death lacked premeditation and may have resulted from an accidental fall rather than a deliberate blow.

Decision Breakdown

The Supreme Court upheld the conviction, relying on the consistent and corroborated testimony of the three injured grandchildren (eyewitnesses) and a neighbour, all of whom described the accused arriving armed with an axe and a cutting weapon and attacking the household. Although the defence argued the fatal head injury could have resulted from an accidental fall (as the doctor could not rule this out), the Court held that the eyewitness testimony of a deliberate blow with the reverse side of an axe, fully corroborated by medical evidence of the injuries, established intent and overt acts sufficient for murder, not a lesser degree of culpable homicide. The Court also rejected the argument that the witnesses' relationship to the deceased made their testimony unreliable, since they were also injured victims of the same incident.

Lesson Learnt

Testimony from witnesses who are relatives of a victim is not automatically suspect, especially where the witnesses were also injured in the same incident, and courts will convict for murder where deliberate, corroborated violence with a deadly weapon is proven, even if a defence theory (like an accidental fall) is medically possible but unsupported by the weight of the evidence.

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

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