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Supreme Court of India 2023-07-20 partly_allowed

ANBAZHAGAN vs THE STATE REPRESENTED BY

Bench: 2 — B.R. Gavai, J.B. Pardiwala

In Brief

An agricultural dispute escalated into violence when the appellant struck the deceased with a weed axe during an argument over use of a pathway, resulting in the deceased's death from head injuries. The appellant was convicted of culpable homicide under Section 304 Part I and sentenced to ten years' imprisonment. The Supreme Court, focusing on the distinction between 'intention' and 'knowledge' in criminal law, held that the circumstances—a sudden quarrel without premeditation, a single blow, and evidence suggesting the appellant knew the act was likely to cause injury that could cause death (rather than intending death itself)—warranted reducing the conviction to Section 304 Part II. The sentence was reduced to five years' rigorous imprisonment.

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Criminal Law Murder and Culpable Homicide Mens Rea Intention and Knowledge Indian Penal Code

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