The Supreme Court of India has upheld the life imprisonment sentence of Kunhimuhammed alias Kunheethu in a case of politically motivated murder in Kerala. The judgment, delivered on December 6, 2024, by a bench comprising Justice Vikram Nath and Justice Prasanna B. Varale, emphasized that even spontaneous acts during altercations can amount to murder if the intent or knowledge of fatal consequences is evident.
Background of the Case
The case stems from a violent political clash between the United Democratic Front (UDF) and the Left Democratic Front (LDF) over election symbol disputes in Pathaikkara Village, Kerala, on April 10, 2006. A scuffle the next day escalated into a fatal attack when the accused, including Kunhimuhammed, assaulted Subrahmannian (the deceased) and another individual, Vasudevan Ramachandra (CW-1).
Kunhimuhammed first used a stick to attack Subrahmannian, who retaliated. In the ensuing melee, the accused stabbed the victim multiple times with a knife, causing fatal injuries to the chest, lungs, and heart. CW-1, who tried to intervene, was also grievously injured. The attack was fueled by prior animosity linked to political affiliations, specifically the Indian Union Muslim League.
Key Legal Issues
The court deliberated on several critical issues:
1. Nature of Intent: Whether the actions of Kunhimuhammed reflected premeditated intent to commit murder or were a spontaneous reaction during the altercation.
2. Extent of Private Defense: The accused claimed to have acted in self-defense, invoking Exception 2 under Section 300 of the Indian Penal Code (IPC).
3. Parity in Sentencing: The appellant sought leniency on grounds of his co-accused receiving reduced sentences and his advanced age with health concerns.
Observations and Findings
1. Intent to Commit Murder: The court analyzed the severity of injuries inflicted on the deceased, emphasizing that deliberate targeting of vital organs with a sharp weapon demonstrated intent. The post-mortem revealed multiple fatal injuries consistent with the prosecution’s narrative. Justice Vikram Nath observed, “No one has a license to inflict injuries that are sufficient to cause death in the ordinary course of nature and claim that they are not guilty of murder.”
2. Rejection of Private Defense: The court found that the injuries sustained by the accused were minor and did not justify the excessive force employed. Highlighting that the accused initiated the attack, the judgment noted that self-defense could not be claimed by aggressors.
3. Denial of Leniency: Citing the heinous nature of the crime, the bench declined to reduce the sentence. It ruled that the appellant’s advanced age and medical conditions, though relevant, did not outweigh the severity of the offense or its implications for public order.
Role of Evidence
The judgment relied heavily on eyewitness accounts, medical reports, and forensic evidence. PW-1, an injured eyewitness, provided consistent testimony corroborated by medical records. The murder weapon, recovered based on the appellant’s disclosure, bore human blood matching the deceased’s blood group.
Final Judgment
The Supreme Court dismissed the appeal for reduction of the sentence, affirming the findings of the lower courts. The appellant’s actions, it concluded, amounted to culpable homicide amounting to murder under Section 302 IPC.
