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State of Madhya Pradesh v. Harjeet Singh & Anr.

Criminal Appeal · 2019 INSC 224Decided 19 Feb 2019
Criminal Appeal No. 1190 of 2009
Justice L. Nageswara Rao · Justice Indu Malhotra

Background

During a dispute linked to pending court litigation, Harjeet Singh allegedly stabbed the complainant Sukhdev multiple times outside a District Court in Madhya Pradesh in 1997, while a co-accused, Ramji Lal, allegedly held back the complainant's brothers. The trial court convicted both men of attempt to murder under Section 307 IPC, but the Madhya Pradesh High Court reduced Harjeet Singh's conviction to the lesser offence of voluntarily causing hurt (Section 324 IPC) and acquitted Ramji Lal, reasoning that the injuries were not on "vital" body parts and that witness accounts about Ramji Lal's role were inconsistent. The State of Madhya Pradesh appealed to the Supreme Court against the reduction in Harjeet Singh's conviction.

Decision Breakdown

The Supreme Court held that the High Court had misread the medical evidence: the chest wound had in fact caused blood to seep into the complainant's lung, contrary to the High Court's finding that the lung was unaffected. The Court reiterated that Section 307 IPC does not require a fatal or "vital-part" injury; intention to kill can be inferred from the weapon used, the nature and severity of the injuries, and the surrounding circumstances, including the pre-existing dispute that supplied a motive. Finding the prosecution's ocular evidence (two eyewitness brothers and an independent advocate-witness) fully corroborated by the medical record, the Court restored Harjeet Singh's original conviction and five-year sentence under Section 307 IPC. The Court upheld the acquittal of the co-accused Ramji Lal, agreeing that inconsistent witness statements about his specific role did not establish common intention beyond reasonable doubt.

Lesson Learnt

A criminal charge of attempt to murder does not depend on whether the injury struck a "vital" organ: intent can be proved through the weapon, the manner of attack, and the circumstances, and appellate courts must read medical evidence accurately before downgrading a conviction.

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

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