In a landmark ruling, the Supreme Court of India has clarified that the minor nature of injuries sustained by a victim is not a sufficient reason to dismiss charges under Section 307 of the Indian Penal Code (IPC), which deals with attempt to murder. The judgment was delivered in the case of Shoyeb Raja v. State of Madhya Pradesh & Ors. (Criminal Appeal No. 3327 of 2024), where the Supreme Court overturned an order from the Madhya Pradesh High Court that had rejected the framing of charges under Section 307 IPC due to the seemingly minor nature of the injuries sustained by the complainant.
Background of the Case
The appellant, Shoyeb Raja, serving as Chairman of the District Waqf Board, Seoni, was allegedly assaulted by members of a previous Masjid Committee during a dispute. According to Raja, the accused verbally abused him, assaulted him, and pressed his mouth, nose, and throat, leading to his hospitalization. The incident led to the filing of an FIR under Sections 294, 323, 506, and 34 of the IPC, and later, charges were framed under Sections 294, 332/34, and 307 IPC (attempt to murder).
However, the High Court of Madhya Pradesh dismissed the Section 307 IPC charge, arguing that the injuries sustained were minor and insufficient to justify an attempt to murder charge.
Legal Issues Involved
The key legal issue before the Supreme Court was whether the absence of severe injuries could lead to the dismissal of charges under Section 307 IPC, which pertains to attempt to murder. Section 307 IPC does not require that the injuries inflicted be life-threatening but that the accused acted with the intent to cause death or grievous bodily harm.
The complainant, Shoyeb Raja, contended that even though the injuries were not severe, the accused’s actions demonstrated an intent to cause serious harm or even death, and therefore, the framing of charges under Section 307 IPC was appropriate.
Court’s Observations
The Supreme Court, in a bench comprising Justices Sanjay Karol and C.T. Ravikumar, disagreed with the High Court’s dismissal of the charges under Section 307 IPC. The Court highlighted that the minor nature of the injuries should not be the sole criterion for determining whether an attempt to murder charge can be framed. The Court emphasized that intent, not just the extent of injuries, is central to cases under Section 307 IPC.
Quoting its previous rulings, the Supreme Court stated:
“It is not essential for a conviction under Section 307 IPC that bodily injury capable of causing death must have been inflicted. The intention or knowledge of the accused, demonstrated through their actions, is of paramount importance.”
The Court further noted that even if the injuries were minor, the medical report, which pointed to signs of throttling, indicated a dangerous act with the potential to cause grievous harm or death. This, the Court observed, was sufficient for the framing of charges under Section 307 IPC.
Key Legal Precedents
The Court cited important precedents to bolster its reasoning. It referred to the case of Hari Mohan Mandal v. State of Jharkhand, where it was held that the extent of injury is irrelevant if the act is done with the intent to cause death or grievous bodily harm. The Court also reiterated the principle that at the stage of framing charges, detailed examination of evidence is not required—what is necessary is a prima facie case showing intent to cause serious harm.
The Decision
The Supreme Court set aside the Madhya Pradesh High Court’s order dated November 23, 2023, and directed that the accused be tried under Section 307 IPC, along with other charges. The Court stated:
“The minor nature of injuries is not a sufficient reason to dismiss charges under Section 307 IPC. What matters is the intention of the accused, and the circumstances under which the act was committed.”
The Court directed that the trial be expedited and conducted on its own merits, without being influenced by observations made during the appeal process.
