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Supreme Court of India 2019-07-09 partly_allowed

Sita Ram vs State of NCT of Delhi

Bench: 2 — Banumathi

In Brief

In this 2019 appeal, the Supreme Court examined whether a murder conviction could be sustained where a fatal attack arose from a sudden quarrel without premeditation. The appellant was convicted along with three others of murdering Mangal Singh with hockey sticks and dandas after he questioned one of them about illegal electricity tapping. The Court found the killing occurred in the heat of passion without prior planning, the accused were not pre-armed, and no undue advantage was taken. The Court modified the conviction from murder (Section 302) to culpable homicide (Section 304 Part II IPC), bringing it within Exception 4 to Section 300, and partly allowed the appeal.

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Criminal Law Murder Exception to Murder Heat of Passion Sudden Quarrel Premeditation

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