Sanjay v. State of U.P.
Background
Sanjay and his brother-in-law Narendra were convicted of murdering Roop Singh and attempting to murder his wife, Sheela, over a land dispute, after firing country-made pistols at them during a night-time attack in 1998. Roop Singh was operated on, discharged from hospital in stable condition, but died 62 days later from septicaemia linked to his wound. The trial court and the Allahabad High Court both convicted the appellants of murder; they appealed to the Supreme Court, which had earlier limited the appeal to the question of what offence was actually made out.
Decision Breakdown
The Supreme Court held that since Roop Singh survived in a stable condition for 62 days after being shot and ultimately died of septicaemia, a complication rather than a direct, immediate result of the gunshot, the prosecution had not proved that the head injury was, by itself, sufficient in the ordinary course of nature to cause death. This meant the stricter murder provision (Section 300, clause 3, IPC) was not made out. The Court therefore downgraded the conviction of both appellants from murder (Section 302 IPC) to culpable homicide not amounting to murder (Section 304 Part I IPC), while upholding their convictions and sentences on the other charges (attempt to murder and house-trespass), and sentenced each to ten years' rigorous imprisonment for the modified offence, running concurrently with the other sentences.
Lesson Learnt
Whether an assault amounts to murder or the lesser offence of culpable homicide can turn heavily on the medical timeline: if a victim survives in a stable condition for a significant period before dying of a complication like infection, the prosecution must specifically establish that the original injury was, by itself, sufficient to cause death in the ordinary course of nature; otherwise the charge may be reduced.