In a significant judgment dealing with the fine distinctions between murder and culpable homicide, the Supreme Court of India has modified the conviction of Ravinder Kumar @ Raju from Section 302 IPC (murder) to Section 304 Part I IPC (culpable homicide not amounting to murder). The Court held that a single blow with an iron rod during a sudden provocation and in the absence of premeditation does not constitute murder under the Indian Penal Code.
The verdict was delivered by a two-judge bench comprising Justice Sudhanshu Dhulia and Justice K. Vinod Chandran in Criminal Appeal No. ___ of 2025 arising out of Special Leave Petition (Crl.) No. 5690 of 2020. The appeal challenged the conviction and life sentence imposed by the lower courts on the appellant for the death of a man during a road rage incident.
Background of the Case
The incident dates back to a road accident in Punjab involving a three-wheeler and a scooter. The appellant, Ravinder Kumar @ Raju, was one of the three men in the three-wheeler that had allegedly collided with the scooter and fled the scene. The scooter rider escaped unhurt, but was soon joined by a colleague and three others, including the deceased and his father. Together, they pursued the offending vehicle.
Upon confrontation, a verbal altercation broke out between the groups. During the heat of the moment, Ravinder Kumar picked up an iron rod from the vehicle and struck a single blow on the head of the deceased, leading to fatal injuries. The victim succumbed to his injury five days later. Notably, the FIR was registered only after the victim’s death, although an initial Daily Diary Report (DDR) had been lodged earlier.
Key Legal Issues
The primary issue before the Supreme Court was whether the incident amounted to murder under Section 302 IPC or whether it fell within the scope of culpable homicide not amounting to murder under Section 304 IPC.
The Court confined itself to examining the “nature of the offence”—whether the circumstances and facts supported a conviction for murder or a lesser offence.
Supreme Court’s Reasoning and Observations
The bench observed that there was no prior motive or premeditation on the part of the accused. The confrontation was a spontaneous reaction to the hit-and-run incident, and the aggression came from the group including the deceased.
“It was in the course of such altercation that the blow was inflicted… There cannot be any intention to cause death alleged but there is definitely an intention to cause bodily injury which resulted in the death,” the Court said.
Further, the Court took note of the fact that the blow, though fatal, was a single strike to the head, inflicted during a heated argument. This, according to the bench, attracted Exception 1 to Section 300 IPC, which states that culpable homicide is not murder if the offender, while deprived of self-control by grave and sudden provocation, causes death.
“The offender-appellant herein could be said to have acted under sudden provocation, thus being deprived of the power of self-control,” the judgment noted.
Modified Sentence
The Supreme Court concluded that the appellant was guilty under Section 304 Part I IPC, which deals with culpable homicide not amounting to murder when the act is done with the intention of causing bodily injury likely to cause death.
The life sentence was reduced to seven years of rigorous imprisonment, while the earlier imposed fine of ₹2,000 and default sentence of two months’ RI were upheld.
“In the totality of the circumstances based on the evidence led, we are of the opinion that the sentence has to be of 7 years rigorous imprisonment,” the Court held.
