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Supreme Court of India 2020-09-09 partly_allowed

Stalin vs State represented by the Inspector of Police

Bench: 3 — Ashok Bhushan, R. Subhash Reddy, M. R. Shah

In Brief

Stalin was convicted of murder (Section 302 IPC) for stabbing Kalidas during a scuffle at a beer party. The Supreme Court held that while a single blow can theoretically attract Section 302, the nature of the offence depends on totality of circumstances. Here, though the stab was on a vital part using a knife, the sudden quarrel context without premeditation, without undue advantage, invoked Exception IV to Section 300 IPC. The Court downgraded the conviction to culpable homicide under Section 304 Part I IPC (punishable by 8 years imprisonment), as the blow with a weapon on a vital body part inherently displayed knowledge that death would result, though not deliberate intent to kill.

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Criminal Law Homicide Section 302 IPC Section 304 IPC Murder v. Culpable Homicide Intention Evidence Single Blow Doctrine

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