In a significant judgment, the Supreme Court of India has altered the conviction of Hare Ram Yadav, a resident of Bihar, from murder under Section 302 of the Indian Penal Code (IPC) to culpable homicide not amounting to murder under Section 304 (Part-I) IPC. The apex court, citing “grave and sudden provocation” as the reason for the incident, reduced Yadav’s life sentence to the time he has already served in custody—over nine years.
The judgment, delivered by a bench comprising Justice B.R. Gavai and Justice K.V. Viswanathan, highlights the importance of understanding the nuances of intent, provocation, and the heat of the moment in criminal cases.
The Case Background
The case revolved around a tragic incident that occurred on November 9, 2015, in Manjhi, Bihar. Hare Ram Yadav, a tenant of the deceased’s family, had a heated argument with Lilawati Devi, wife of the informant, Ranglal Yadav (PW-5). The dispute arose over the removal of bricks belonging to Yadav, which escalated into a confrontation.
During the altercation, witnesses testified that Lilawati Devi challenged Yadav by saying he could act if he dared. Provoked by her remarks, Yadav stabbed her with a knife, causing fatal injuries. She succumbed to her injuries during treatment at a local hospital.
An FIR (No. 221 of 2015) was promptly registered, and Yadav was arrested. The Trial Court convicted him under Section 302 IPC, sentencing him to life imprisonment. The Patna High Court upheld this conviction, leading Yadav to appeal before the Supreme Court.
Legal Issues
The Supreme Court focused on two crucial aspects:
1. The Credibility of Witnesses: The defense argued that all five eyewitnesses, including the informant Ranglal Yadav, were relatives of the deceased, making their testimonies biased. However, the court rejected this argument, stating that familial ties alone do not discredit testimony if it withstands cross-examination.
2. The Nature of the Crime: The appellant’s counsel, Smarhar Singh, argued that the crime was not premeditated but occurred in the heat of the moment during a quarrel. He claimed that the case fell under the exceptions to murder outlined in Section 300 IPC and should be treated as culpable homicide. The prosecution, represented by Azmat Hayat Amanullah, contended that the fatal injury to a vital body part indicated intent, warranting a conviction under Section 302 IPC.
Supreme Court’s Observations
The bench examined the evidence presented, including the testimonies of five eyewitnesses and the post-mortem report. Key observations included:
– Absence of Premeditation: The court found no evidence suggesting that the act was planned. The altercation erupted over a trivial matter and escalated due to provocation.
– Grave and Sudden Provocation: The deceased’s remarks provoked Yadav, leading to the fatal act in a fit of rage. “The incident occurred in the heat of anger, without premeditation, during a grave and sudden fight,” observed the court.
– Single Injury and Lack of Cruelty: The court noted that Yadav inflicted only one stab wound and did not act with undue cruelty or advantage.
These factors led the bench to conclude that Yadav’s actions met the criteria for exceptions under Section 300 IPC, warranting a lesser charge of culpable homicide under Section 304 (Part-I) IPC.
Verdict and Sentencing
The Supreme Court reduced Yadav’s conviction to Section 304 (Part-I) IPC, sentencing him to the period already served—over nine years in custody. It directed his immediate release, provided no other cases were pending against him. The court also allowed Yadav two weeks to pay any pending fines imposed by the Trial Court.
Case Details
– Case Title: Hare Ram Yadav v. State of Bihar
– Case Number: Criminal Appeal No. 4952 of 2024
– Bench: Justice B.R. Gavai and Justice K.V. Viswanathan
– Appellant’s Counsel: Smarhar Singh
– Prosecution Counsel: Azmat Hayat Amanullah
