In a significant ruling reflecting on the consequences of long-pending criminal appeals, the Supreme Court of India dismissed a criminal appeal by the State of Madhya Pradesh in State of Madhya Pradesh v. Shyamlal & Others [Criminal Appeal No. 1254 of 2024], upholding the Madhya Pradesh High Court’s decision to convert a murder conviction into one under culpable homicide not amounting to murder. The apex court cited serious doubts over the cause of death, the age of the accused, and an extraordinary delay of over three decades in concluding the trial and appeals process.
Background of the Case
The case stemmed from a violent incident that occurred on November 1, 1989, in the Chhatarpur district of Madhya Pradesh. It was alleged that Shyamlal and his co-accused, believing that one Siroman (PW-1) had cut the tail of their buffalo, attacked him and others with sticks and ballams (spears). During the incident, multiple people sustained injuries, including Laxman, who died 15 days later.
Initially, the Trial Court had convicted all the accused under Sections 147, 452, 302, 325, and 323 read with Section 149 of the Indian Penal Code (IPC) and sentenced them to life imprisonment under Section 302/149 IPC. However, in 2017, the Madhya Pradesh High Court set aside the murder conviction, altering it to an offence under the second part of Section 304 IPC (culpable homicide not amounting to murder) and sentenced the aged accused to the period already undergone—just 76 days in jail. Each was fined ₹16,000, with ₹1 lakh allocated to the deceased’s family as compensation.
Legal Issues and Supreme Court’s Analysis
The State challenged the High Court’s decision, arguing that the injuries and nature of the assault clearly established intent and knowledge to kill, warranting a conviction under Section 302 IPC.
Appearing for the State, Advocate Nitin Talreja contended that over 35 grievous injuries were inflicted during the attack, including on the deceased. He emphasized that Dr. Baburam Arya (PW-17), who treated the deceased, had reported serious injuries to the skull and face. Talreja relied on Ahmed Hussein Vali Mohammed Saiyed & Anr. v. State of Gujarat (2009) to stress that criminal sentencing must not be so lenient as to “shock the conscience of the court.”
Defending the High Court’s decision, the legal aid counsel appointed for the respondents pointed out that the post-mortem did not definitively link the injuries to Laxman’s death. The cause of death was listed as asphyxia, but no internal organ damage or poisoning was detected. Dr. Arya had explicitly stated in his deposition:
“Laxman had died due to suffocation. It was difficult to give a definite reason.”
The three-judge bench—comprising Justice Abhay S. Oka, Justice Ahsanuddin Amanullah, and Justice Augustine George Masih—carefully analyzed the medical and factual evidence. They noted:
“Neither the cause of death mentioned in the post-mortem report nor the evidence of PW-17 prove that the injuries inflicted upon the deceased resulted in his death… there is a serious doubt whether even Section 304 of the IPC could have been applied.”
Yet, since the respondents had not appealed against the Section 304 conviction, the Court declined to interfere. It found the High Court’s reasoning “fair and appropriate,” especially given that all the surviving accused were aged 70 to 80 and the incident occurred 36 years ago.
In a noteworthy postscript, the Court reflected on the systemic delays in hearing criminal appeals:
“If the appeals against conviction where the accused are on bail and especially where a life sentence has been imposed are heard after a decade or more… the question arises of sending the accused back to jail after a long period of more than a decade.”
The Court emphasized that “a right balance has to be struck” and suggested that appeals involving elderly convicts or significant time lapses should be prioritized, even if the accused are on bail.
