Supreme Court Affirms Murder Conviction: Armed Trespass and Fatal Blow Over Land Dispute.


02 April 2025 Criminal Appeals & Suspension of Sentence >> Criminal Law   |   Murder Homicide >> Criminal Law  

The Supreme Court in Maukam Singh & Others v/s State of Madhya Pradesh., upheld the conviction and life sentence of three appellants for the murder of the deceased and causing injuries to his three grandchildren. The incident stemmed from the accused's annoyance over the worship of a deity on disputed land by one of the injured. The prosecution's case was that the accused, instigated by the land possessor, went to the deceased's house armed with weapons, leading to a fatal scuffle.

The appellants argued lack of premeditation or intent to cause death, highlighting that the deceased's fatal head injury might have been caused by an accidental fall despite the witnesses mentioning cutting weapons. The respondent-State countered with the consistent testimony of the injured eyewitnesses (grandchildren) stating that the accused trespassed and attacked with deadly weapons without provocation. The State argued that the single blow to the head caused the death, regardless of the time elapsed before death.


 

 

The Supreme Court scrutinized the evidence, noting that the eyewitnesses being related to the deceased did not automatically discredit their testimony. The Court found the prosecution unequivocally proved the altercation occurred in the deceased's house after the accused arrived with deadly weapons, intending harm. Testimony from a neighbor corroborated the animosity over the place of worship and the accused being armed.

While acknowledging the "double-edged sword" of motive, the Court found the eyewitnesses' accounts credible, especially since they were all injured in the same incident. Their testimonies regarding the accused coming with weapons and inflicting blows, including a blow to the deceased's head, were largely consistent with the medical evidence of injuries sustained by the deceased and the grandchildren.

The Court rejected the argument that the fatal injury could have been from an accidental fall, given the corroborated testimony of a blow to the head with the reverse side of an axe. The Court reasoned that in a scuffle, precise details of weapon usage might not be perfectly recalled, but the overt act of a blow to the head was established.

The Court concluded that the accused came to the house armed with deadly weapons with the intention to cause injuries likely to cause death, negating any claim for conviction under a lesser charge of culpable homicide not amounting to murder or any exceptions to murder. The medical evidence of a fatal head injury, consistent with the eyewitness accounts of a blow to a vital part of the body with a deadly weapon, supported the conviction under Section 302 of the Indian Penal Code.


Section 302., Indian Penal Code - 1860  

Indian Penal Code, 1860