VidhiSangh

Supreme Court of India · 09/09/2020

STALIN versus STATE REPRESENTED BY THE INSPECTOR OF POLICE

[2020] 7 S.C.R. 283 · 2020 INSC 540

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Summary

The Court altered murder to culpable homicide under Section 304 Part I after a sudden quarrel among friends at a beer gathering led to a knife stabbing. A single injury did not automatically exclude murder; the surrounding circumstances and sudden-fight exception governed. Because the knife caused injury to a vital part, Part I rather than the requested Part II applied. The Court imposed eight years’ rigorous imprisonment and a fine.

Issues

  1. Whether a single-blow case necessarily excluded murder.
  2. Whether the sudden-fight exception applied and the conviction fell under Part I or Part II of Section 304.
  3. Whether absence of established motive defeated reliable eyewitness evidence.

Provisions considered

Held

Result

Appeal partly allowed; Section 302 conviction replaced by Section 304 Part I. Sentence fixed at eight years’ rigorous imprisonment and Rs.10,000 fine, with one further year’s rigorous imprisonment in default.

Judgment PDF: Supreme Court of India, [2020] 7 S.C.R. 283.