From Murder to Manslaughter: A Court’s Reassessment of Intent.
24 September 2024
Criminal Appeals & Suspension of Sentence >> Criminal Law | FIR >> Criminal Law | Investigation >> Criminal Law | Murder Homicide >> Criminal Law
The appeals before the Supreme Court challenge the judgment delivered on June 26, 2023, by the Delhi High Court, which dismissed the appeals of the appellants, Sunil Sonu and Nitin Devender. The High Court upheld the trial court's conviction of the appellants for murder under Section 302 read with Section 34 of the Indian Penal Code (IPC) and affirmed their life sentences along with a fine.
Facts of the Case:
The incident in question occurred on November 28, 2016, when Rahul (PW-1) and Sachin (the deceased) encountered Sunil Sonu and his associates, leading to a verbal altercation. The situation escalated into physical violence, with the appellants allegedly attacking Sachin with knives after he attempted to flee. Shivani (PW-2), who witnessed the attack, intervened and sought police assistance, leading to the eventual arrest of the accused. 
Sachin was transported to a hospital but succumbed to his injuries, prompting the addition of murder charges against the appellants. The prosecution built its case on the testimonies of multiple witnesses, including Rahul and Shivani.
Legal Proceedings:
The trial court found the appellants guilty of murder, asserting that they had acted with intent to kill. The High Court affirmed this decision, leading to the present appeals.
Arguments from the Defense:
The appellants contended that the prosecution failed to explain the injuries they sustained during the incident, which they claimed arose from a prior altercation initiated by Rahul and Sachin. They highlighted delays in lodging the FIR, emphasizing that Rahul did not report the incident until more than 24 hours later. Additionally, they argued that Shivani's testimony was biased due to her relationship with Rahul.
Court's Analysis:
Upon reviewing the case, the Supreme Court found significant inconsistencies in the prosecution's narrative. The delay in lodging the FIR was seen as problematic, as were the contradictions in the testimonies of key witnesses. The Court noted that the injuries sustained by the appellants remained unexplained, raising doubts about the prosecution's version of events.
The Court recognized the possibility of a sudden fight, suggesting that the appellants could have acted in the heat of the moment without premeditation. This assessment led to the conclusion that the actions of the appellants, while resulting in death, did not meet the threshold for murder under Section 302 of the IPC.
Conclusion:
The Supreme Court partly allowed the appeals, reducing the charges from murder to a lesser offense under Part I of Section 304 of the IPC, reflecting a more nuanced understanding of the circumstances surrounding the incident. The appellants, having served over eight years in custody, were ordered to be released if not required in other cases.
This judgment underscores the importance of a careful examination of the facts and circumstances in criminal cases, particularly regarding the intent and premeditation required for a murder conviction.