Madhya Pradesh High Court Reclassifies Murder Conviction as Culpable Homicide Not Amounting to Murder

Madhya Pradesh High Court Reclassifies Murder Conviction as Culpable Homicide Not Amounting to Murder

By Abhishek Jat, Advocate

Citation:

X v State of Madhya Pradesh, Madhya Pradesh High Court, Judgment dated 1 July 2025

Coram:

Justice Vijay Kumar Shukla and Justice Prem Narayan Singh

Case Background

The Madhya Pradesh High Court recently adjudicated upon an appeal concerning the conviction of an individual for the death of his wife following a domestic altercation. The appellant, convicted by the trial court under Section 302 of the Indian Penal Code (IPC) for murder and sentenced to life imprisonment, challenged the verdict, asserting the absence of intent to kill.

Factual Matrix

The incident originated from a domestic dispute over a monetary demand. The appellant, in a heated exchange with his wife, physically assaulted her and subsequently inflicted a fatal head injury using a brick. Witness testimonies indicated that the altercation was spontaneous, escalating rapidly without premeditation. The couple’s son and a relative attempted to intervene, but the appellant persisted, ultimately locking his son in a room. The following morning, the deceased was discovered with a fatal head wound.

Trial Court Proceedings

The prosecution presented nine witnesses, including family members and the medical officer. Notably, most witnesses, including the couple’s son, turned hostile, failing to fully corroborate the prosecution’s narrative. The medical evidence, however, established that the fatality resulted from a hard and blunt object, consistent with the use of a brick. The trial court convicted the appellant under Sections 342 and 302 IPC.

Arguments on Appeal

• For the Appellant: Advocate Manohar Singh Chouhan contended that the incident was a sudden outcome of a domestic quarrel, devoid of homicidal intent, and thus should be classified under Section 304 Part II IPC (culpable homicide not amounting to murder) rather than Section 302 IPC (murder).

• For the State: Deputy Advocate General Shrey Raj Saxena, assisted by Government Advocate H.S. Rathore, maintained that the conviction was justified based on medical and circumstantial evidence, urging the court not to show leniency.

Court’s Analysis and Reasoning

The Division Bench scrutinised the evidence, particularly the statements recorded under Section 164 of the Code of Criminal Procedure (CrPC) and the forensic findings. The bench observed:

"There was a sudden scuffle between the appellant and the deceased due to non-fulfilment of demand... in the heated spur of moment, the incident had happened... Brick has been pelted on head of deceased with full force in a heated moment. Thus, in committing so, the appellant was certainly having the knowledge of death, but not the intention."

The court emphasised the absence of premeditation and the lack of clear intent to kill. The altercation, it found, was an impulsive escalation of a domestic dispute. The hostile stance of key witnesses and lack of evidence suggesting a motive beyond the domestic quarrel further influenced the court’s assessment.

Modification of Conviction

Given the circumstances, the court concluded that the appellant possessed knowledge that his actions were likely to cause death but did not harbour the specific intent required for a murder conviction under Section 302 IPC. Consequently, the conviction was modified to Section 304 Part II IPC, which pertains to culpable homicide not amounting to murder when the act is done with knowledge but without intention to cause death.

Key Legal Principles and Glossary

Term/Section	Meaning
Section 302 IPC	Punishment for murder; requires proof of intention to cause death or bodily injury likely to cause death.
Section 304 Part II IPC	Punishment for culpable homicide not amounting to murder, where the act is done with knowledge but without intention to cause death.
Hostile Witness	A witness who retracts or contradicts their previous statement during trial.
Section 164 CrPC	Provision for recording confessions and statements before a magistrate.
Forensic Evidence	Scientific analysis of physical evidence, such as bloodstains, to establish facts in a case.

Conclusion

This judgment underscores the nuanced distinction between murder and culpable homicide not amounting to murder under Indian criminal law. The Madhya Pradesh High Court’s approach highlights the importance of intent, the spontaneity of the act, and the evidentiary value of both medical and witness testimonies—even when witnesses turn hostile. The decision serves as a significant precedent for cases involving domestic altercations resulting in fatal outcomes, reinforcing the judicial imperative to differentiate between knowledge and intention in criminal liability.

Disclaimer: This article is intended for informational and academic purposes only. It does not constitute legal advice or create an attorney-client relationship. Readers are encouraged to consult a qualified legal professional for advice regarding specific legal issues or cases. The views expressed herein are those of the author and do not represent the official position of any organization or institution.
Copyright Notice: © 2025 Abhishek Jat, Advocate. All rights reserved. No part of this article may be reproduced, distributed, or transmitted in any form or by any means, including photocopying, recording, or other electronic or mechanical methods, without the prior written permission of the author. Unauthorized use or reproduction of this material is strictly prohibited and may result in legal action.