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Pillu @ Prahlad vs The State of Madhya Pradesh

Criminal Appeal · 2022 INSC 936Decided 7 Sept 2022
Criminal Appeal No. 1331 of 2011
Dinesh Maheshwari · Bela M. Trivedi

Background

The appellants had been convicted by a trial court under Section 302 read with Section 34 of the Indian Penal Code (murder, with common intention) for the killing of a man named Sanju, and were sentenced to life imprisonment with a fine. The Madhya Pradesh High Court had dismissed their appeal and upheld the conviction. The appellants challenged this before the Supreme Court, arguing that key prosecution witnesses were unreliable, one had turned hostile and another was introduced as an eyewitness only 22 days after the FIR was filed, and alternatively argued that even on the prosecution's own version, the offense should be downgraded to culpable homicide not amounting to murder under Exception 4 to Section 300 IPC (which applies to sudden fights without premeditation).

Decision Breakdown

The Supreme Court held that the trial court and High Court had thoroughly examined the witness testimony, including that of the injured first informant, and their factual findings on the appellants' guilt were well-founded, warranting no interference. On the Exception 4 argument, the Court held it was inapplicable because the evidence showed the killing was not a sudden, unplanned fight: the victim had been assaulted after the appellants tried to pressure him not to testify in another criminal case, and the injuries (multiple incise and stab wounds including to the skull and chest) indicated a deliberate, not impulsive, act. The appeals were dismissed and the murder conviction upheld.

Lesson Learnt

Appellate courts will generally not disturb concurrent factual findings on witness credibility reached by the trial court and the first appellate court; and a killing preceded by premeditated pressure or threats, rather than a spontaneous quarrel, will not qualify for the reduced culpability available under the "sudden fight" exception to murder.

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

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