VidhiSangh

Supreme Court of India · 27/08/2019

KHUMAN SINGH versus STATE OF MADHYA PRADESH

[2019] 11 S.C.R. 270 · 2019 INSC 965

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Summary

For a 2005 killing arising from a sudden quarrel over grazing buffaloes, the Court modified the murder conviction to culpable homicide under section 304 Part II IPC and imposed imprisonment already undergone. It accepted the eyewitness account of the axe assault but found no premeditation and applied Exception 4 to section 300. It separately set aside the conviction under section 3(2)(v) of the SC/ST Act because the evidence did not establish the caste-based ground required in its analysis of that charge.

Issues

  1. Whether the fatal axe assault during a sudden grazing dispute fell within Exception 4 to section 300 IPC.
  2. Whether the evidence sustained the additional conviction under section 3(2)(v) of the SC/ST Act for this 2005 incident.

Provisions considered

Held

Result

Appeal partly allowed. Section 302 IPC conviction modified to section 304 Part II with imprisonment already undergone; acquitted of the section 3(2)(v) SC/ST Act charge. Immediate release ordered unless required in another case.

Judgment PDF: Supreme Court of India, [2019] 11 S.C.R. 270.