Court’s Decision:
The Supreme Court of India partly allowed the appeals, altering the conviction of the appellants from Section 302 of the Indian Penal Code (IPC) to Part-I of Section 304 IPC. The appellants, having already undergone more than 8 years of imprisonment, were sentenced to the period already undergone and directed to be released forthwith if not required in any other case.
Facts:
The prosecution’s case was based on an incident that occurred on 28th November 2016, where the appellants were accused of fatally attacking the deceased and injuring a witness following a verbal altercation. The appellants were convicted under Section 302 IPC for causing the homicidal death of the deceased, and the trial court sentenced them to life imprisonment, which was upheld by the High Court.
Issues:
The primary legal issue was whether the appellants’ conviction under Section 302 IPC was justified or if the facts of the case necessitated a conviction under a lesser offence, such as Part-I of Section 304 IPC.
Petitioner’s Arguments:
The appellants argued that the prosecution failed to explain the injuries sustained by them during the incident. They also claimed that the delay in filing the FIR and contradictions in the testimonies of key witnesses weakened the prosecution’s case. Additionally, the appellants contended that the FIR was a counterblast to an earlier FIR lodged by them.
Respondent’s Arguments:
The respondent-State argued that both the trial court and the High Court had correctly appreciated the evidence, proving the prosecution’s case beyond reasonable doubt. It was contended that no interference with the conviction was warranted.
Analysis of the Law:
The Court considered the evidence, including the medical reports and testimonies, and noted that the prosecution had established that the appellants had caused the injuries leading to Sachin’s death. However, the Court also acknowledged that there were certain contradictions and the failure to explain the injuries sustained by the appellants.
Precedent Analysis:
The Court examined relevant legal principles, particularly those relating to culpable homicide and sudden provocation, to determine whether the appellants’ actions fell within the scope of Section 302 IPC or Part-I of Section 304 IPC.
Court’s Reasoning:
The Court found that the prosecution’s failure to explain the injuries sustained by the appellants and the possibility of the offence being committed in the heat of passion without premeditation indicated that the appellants were entitled to the benefit of doubt. The Court concluded that the case fell under Part-I of Section 304 IPC rather than Section 302 IPC, as there was no evidence of premeditation or cruel and unusual behavior by the appellants.
Conclusion:
The Supreme Court altered the conviction from Section 302 IPC to Part-I of Section 304 IPC and sentenced the appellants to the period already undergone. The Court ordered their release, provided they were not required in any other case.
Implications:
The judgment highlights the importance of considering the possibility of sudden provocation and the absence of premeditation in cases involving homicide, which can lead to a conviction under a lesser charge of culpable homicide not amounting to murder.