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State of Rajasthan v. Ramesh

Criminal Appeal · Neutral citation not assigned (Criminal Appeal No. 1526 of 2008)Decided 20 Nov 2015
Criminal Appeal No. 1526 of 2008
Justice S.A. Bobde · Justice Prafulla C. Pant

Background

In April 1999, Ramesh's daughter Sheela died at the farmhouse where the family lived and worked. The prosecution said he strangled her after he saw her talking with a young man; the defence said she hanged herself. The trial court convicted Ramesh of murder and sentenced him to life imprisonment, but the High Court acquitted him, and the State appealed.

Decision Breakdown

The Supreme Court set aside the High Court's acquittal. It held that the post-mortem findings (asphyxia from pressure on the neck, with no ligature mark) ruled out hanging as a reasonable view, and that the eyewitness accounts proved Ramesh slapped his daughter and caused her death. Because he acted in a sudden loss of self-control after seeing her with the young man, the Court held the case fell within Exception 1 to Section 300 IPC (grave and sudden provocation). It therefore convicted him of culpable homicide not amounting to murder under Section 304 Part I, sentenced him to ten years' rigorous imprisonment, and set off the time already served.

Lesson Learnt

An appeal court can overturn an acquittal where medical and eyewitness evidence clearly contradict the defence account. A sudden loss of self-control after provocation can reduce a murder charge to a lesser offence, but it does not make the killing lawful.

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

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