The Supreme Court of India, in a judgment clarifying the law on homicide, has laid down comprehensive guidelines for courts to determine when an offence constitutes murder under Section 302 of the Indian Penal Code (IPC) versus an attempt to murder under Section 307, particularly in cases where death occurs long after the initial assault due to supervening medical complications.
A bench of Justice J.B. Pardiwala and Justice R. Mahadevan established these principles while adjudicating the case of Maniklal Sahu v. State of Chhattisgarh. The Court held that a delayed death from complications like septicemia does not reduce the culpability from murder if the original injuries were sufficient in the ordinary course of nature to cause death.
The Core Legal Issue: Causation and Delayed Death
The Court addressed a crucial legal question: Does a significant time gap between the infliction of injury and the victim’s eventual death, coupled with intervening medical complications, break the chain of causation and reduce the offence from murder to a lesser charge? The Court’s answer was a firm negative, provided the complications are a direct and natural consequence of the initial injury.
Guidelines Laid Down by the Supreme Court
In its judgment, the Court synthesized the law on causation into several key principles for lower courts to follow:
- Fatal Injury and Intention: If it is proved that the injuries inflicted were intended to cause death and were fatal, it is murder, even if death occurs after several days due to septicemia or other complications.
- Sufficient in Ordinary Course of Nature: If the intended injuries were sufficient in the ordinary course of nature to cause death, the offence is murder, regardless of any subsequent medical complications that are the immediate cause of death.
- Irrelevance of Medical Treatment: In judging whether injuries were sufficient to cause death, “the possibility that skilful and efficient medical treatment might prevent the fatal result is wholly irrelevant.” This is reinforced by Explanation 2 to Section 299 of the IPC.
- Attributable Supervening Causes: If the supervening causes (like infections or organ failure) are attributable to the injuries caused, the person inflicting the injuries is liable for causing death.
- Chain of Causation: The crucial test is whether the chain of causation is broken. If a complication is a natural or probable consequence of the injury, the chain is intact. If an unexpected complication creates a “new mischief,” the connection may be considered too remote. The Court stated, “If the original injury itself is of a fatal nature, it makes no difference that death is actually caused by a complication naturally flowing from the injury.”
- Cumulative Effect of Injuries: Even if no single injury is sufficient to cause death, the cumulative effect of all injuries can be sufficient in the ordinary course of nature to cause death, thereby justifying a murder conviction.
Factual Context: The Maniklal Sahu Case
These principles were applied to a case where the victim, Rekhchand Verma, was thrown from a terrace and assaulted on February 22, 2022. He suffered a severe spinal cord injury, leading to paraplegia. He remained bedridden and died nine months later, on November 8, 2022, from cardiorespiratory arrest caused by septic shock, bilateral pneumonia, and other complications directly stemming from the spinal injury.
The trial court convicted the accused of murder. However, the Chhattisgarh High Court reduced the conviction to attempt to murder, reasoning that the death occurred after nine months due to a “lack of proper treatment.”
Supreme Court’s Rebuke of the High Court
The Supreme Court termed the High Court’s reasoning a “gross error” and “erroneous.” The bench observed it was “taken by surprise” by the finding of “lack of proper treatment,” stating there was “absolutely no evidence in this regard” and that the issue was “wholly irrelevant” under law.
The Court held that the medical evidence clearly established that the septicemia and other complications were a direct result of the spinal injury. The injuries were sufficient in the ordinary course of nature to cause death, squarely placing the offence under “Thirdly” of Section 300 IPC (murder).
Final Verdict
Despite concluding that the offence was clearly murder, the Supreme Court could not restore the conviction under Section 302 IPC. This was because the State of Chhattisgarh had not appealed the High Court’s erroneous decision to reduce the charge. Therefore, while dismissing the convict’s appeal for acquittal, the Court was constrained to uphold the lesser conviction for attempt to murder.
The judgment, however, stands as a significant directive on the application of the theory of causation in homicide cases, clarifying the law for future trials.
