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Ravinder Kumar @ Raju v. State of Punjab

Criminal Appeal · 2025 INSC 396Decided 25 Mar 2025
Crl.A. No.-001494-001494 - 2025
Justice Sudhanshu Dhulia · Justice K. Vinod Chandran

Background

After a three-wheeler hit a scooter and sped off, the injured scooterist and four others, including the eventual victim and his father and brother, chased down the vehicle and confronted its three occupants. During the resulting altercation, the appellant picked up an iron rod and struck one of the pursuing group on the head; the victim died five days later. The trial court convicted the appellant of murder under Section 302 IPC and sentenced him to life imprisonment (the other two co-accused were acquitted), and the Punjab and Haryana High Court upheld this. The Supreme Court had granted limited leave only on the narrow question of whether the offence was really murder or the lesser offence of culpable homicide.

Decision Breakdown

The Supreme Court found there was no motive, premeditation, or intention to kill, rather, the victim's group had itself pursued and confronted the accused (who had fled after the earlier accident), and it was during that heated, unplanned altercation that a single blow was struck with an iron rod. Because the injury was inflicted without premeditation, in a sudden quarrel where the victim's side were effectively the aggressors, and the accused acted under sudden provocation depriving him of self-control, the Court held the case fell within Exception 1 to Section 300 IPC, converting the offence to culpable homicide not amounting to murder under Section 304 Part I (since a single blow to a vital body part likely to cause death was deliberately inflicted). The life sentence was set aside and replaced with 7 years' rigorous imprisonment, with the earlier fine and default sentence left unchanged.

Lesson Learnt

Even a fatal blow struck with a dangerous weapon may not amount to murder if it happens in a sudden, unplanned altercation without premeditation, especially where the deceased's own group provoked the confrontation; such cases can fall under the lesser offence of culpable homicide instead of murder, significantly reducing the punishment.

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

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