VidhiSangh

Supreme Court of India · 12/09/2025

MANIKLAL SAHU versus STATE OF CHHATTISGARH

[2025] 10 S.C.R. 212 · 2025 INSC 1107

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Summary

The victim, thrown from a terrace and beaten, suffered a spinal cord injury causing paraplegia and died about nine months later of septic shock, pneumonia and infected bedsores. The High Court altered the murder conviction to attempt to murder on the ground that death followed late and from want of proper treatment. The Supreme Court held this was a serious error, since the complications flowed from the original injuries and Explanation 2 to Section 299 IPC makes adequacy of treatment irrelevant, and laid down principles for delayed deaths; but as the State had not appealed, it only dismissed the accused's appeal.

Issues

  1. Whether an assault resulting in death some nine months later, from septic shock, pneumonia and infected bedsores following a spinal cord injury, is murder or only attempt to murder.
  2. Whether alleged lack of proper treatment, or a supervening complication, breaks the chain of causation between the injury and the death.
  3. What the ingredients of an offence under Section 307 IPC are and how intention is to be inferred.
  4. Whether the eyewitnesses, who were relatives of the deceased, could be relied upon.

Provisions considered

Held

Result

Appeal by the accused dismissed; conviction under Section 307 IPC as altered by the High Court left undisturbed in the absence of an appeal by the State, though the Court disapproved the High Court's view.

Judgment PDF: Supreme Court of India, [2025] 10 S.C.R. 212.