Prasad Pradhan & Anr. vs The State of Chhattisgarh
Background
On 28 February 2012, Vrindawan was having land near his septic tank levelled with a JCB when his cousins Prasad Pradhan and Lingraj Pradhan, neighbours with whom the family had a long-running land dispute, began abusing him, climbed over the wall armed with axes and attacked him; Prasad struck him on the head and Lingraj on the legs, and when Vrindawan's daughter tried to intervene she was also hit on the leg with an axe. Vrindawan suffered a fractured skull and multiple other injuries, underwent surgery, never left hospital and died 20 days later; the post-mortem attributed death to cardio-respiratory failure resulting from the injuries. The trial court convicted both men (and a third accused, later acquitted by the High Court) of murder and sentenced them to life imprisonment; the Chhattisgarh High Court upheld their conviction, and they appealed to the Supreme Court arguing the eyewitnesses were interested relatives, the incident was a sudden unpremeditated quarrel, and the death, occurring 20 days later, was not directly caused by their blows.
Decision Breakdown
The Supreme Court dismissed the appeal and upheld the murder conviction and life sentences. It held that witnesses being relatives of the deceased does not by itself make them unreliable; the daughter was herself injured in the attack, had no reason to lie, and was corroborated by three other witnesses. Applying the classic tests from Virsa Singh and Rayavarapu Punnayya, the Court found the accused deliberately inflicted axe blows to the head, a vital part, that were sufficient in the ordinary course of nature to cause death, bringing the case within "murder" under Section 300 thirdly. Neither exception applied: there was no "sudden fight" because the accused were the unprovoked aggressors who came armed (showing premeditation) and took undue advantage of an unarmed man, and no "grave and sudden provocation" was shown beyond an old land dispute, with the accused offering no evidence of any trigger. Finally, the Court reiterated that a victim surviving for some days (here 20; in earlier cases 12 to 14 days) does not by itself reduce murder to culpable homicide: what matters is whether the injuries were sufficient to cause death and whether death was directly linked to them, which the medical evidence established.
Lesson Learnt
Arming yourself and attacking an unarmed person on the head over an old grudge is murder, not a lesser offence, even if the victim dies days or weeks later in hospital. The law looks at the nature of the injury intended, not the time death takes. An old quarrel is not "sudden provocation," and the accused bears the burden of showing facts that bring the case within an exception.