The Supreme Court of India recently in Ravinder Kumar @ Raju v/s State of Punjab., modified a conviction from murder under Section 302 of the Indian Penal Code (IPC) to culpable homicide not amounting to murder under Section 304 Part I of the IPC, in a case stemming from a road rage incident. The appellant, who was the sole individual convicted in the case, had originally received a life sentence.

The case originated from a hit-and-run incident where a three-wheeler collided with a scooter. The victim, accompanied by his father and a colleague, pursued the offending vehicle and confronted its occupants. During the ensuing altercation, the appellant allegedly picked up an iron rod and struck the deceased on the head. The victim succumbed to the injury five days later.

While the post-mortem report confirmed a homicidal death from the single head injury and the iron rod was recovered, the Supreme Court's review focused on the nature of the crime rather than the evidentiary details. The Court observed that there was no motive or premeditation alleged against the accused. Crucially, the Court noted that the deceased and his group had chased and confronted the accused, effectively taking the law into their own hands.

The Court reasoned that the fatal blow was inflicted during a sudden altercation, without premeditation. It found that the appellant acted under sudden provocation, being deprived of self-control, and therefore, the act fell under Exception 1 of Section 300 of the IPC, which deals with culpable homicide not amounting to murder. Although there was a clear intention to cause bodily injury, which resulted in death by hitting a vital part of the body, the absence of premeditation and the context of sudden provocation led the Court to conclude that the offense was one of culpable homicide not amounting to murder under Section 304 Part I of the IPC.

As a result, the Supreme Court modified the appellant's conviction from Section 302 to Section 304 Part I of the IPC. The life imprisonment sentence was reduced to seven years of rigorous imprisonment, with the previously imposed fine and default sentence remaining intact. The appellant was directed to surrender within two months if he had not already served the seven-year term.

Section 302., Indian Penal Code - 1860  

Section 304., Indian Penal Code - 1860  

Indian Penal Code, 1860