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The State of Uttarakhand vs Sachendra Singh Rawat

Criminal Appeal · 2022 INSC 153Decided 4 Feb 2022
Criminal Appeal No. 143 of 2022
M.R. Shah · B.V. Nagarathna

Background

During a village wedding "Mehendi" ceremony, the accused and the deceased (Virendra Singh) had a verbal altercation which villagers broke up. Later that night, around midnight, the accused attacked the deceased with a "Phakadiyat" (a rough wooden stick/firewood), chasing him to his house and giving him repeated blows to the head even after the initial confrontation had ended. The deceased suffered a fractured skull and other severe head injuries, and died about ten days later after surgery. The trial court convicted the accused of murder and sentenced him to life imprisonment, but the Uttarakhand High Court reduced this to culpable homicide not amounting to murder (10 years' rigorous imprisonment), reasoning it was a sudden fight in the heat of passion using an ordinary piece of wood, falling under the "Fourth Exception" to Section 300 IPC.

Decision Breakdown

The Supreme Court restored the trial court's murder conviction and life sentence, holding the High Court had erred. It found the fatal attack was a distinct, later incident (occurring at midnight near the deceased's house, well after the earlier ceremony altercation had been resolved by villagers) and therefore could not be treated as part of one continuous "sudden fight in the heat of passion." The Court also emphasised the multiple severe blows to a vital body part (the head, resulting in skull fracture, 34 stitches, and brain laceration), which showed either clear intention or at least knowledge that such an act was likely to cause death, bringing the case within Clauses "Thirdly" and "Fourthly" of Section 300 IPC (definition of murder) rather than the "Fourth Exception" that reduces the offence.

Lesson Learnt

Whether a killing is "murder" or a lesser "culpable homicide" often turns on the nature of the weapon, the part of the body targeted, the number of blows, and whether there was a real, continuous, sudden fight, chasing and repeatedly striking someone's head after an earlier quarrel has already ended will not qualify for the lighter offence merely because an ordinary object was used as the weapon.

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

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