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Supreme Court of India 2018-12-13 allowed

State of Rajasthan vs Leela Ram @ Leela Dhar

Bench: 2 — Dhananjaya Y. Chandrachud

In Brief

In this murder appeal, the Supreme Court examined whether an axe blow to the deceased's skull constituted murder or culpable homicide. The High Court had reduced the conviction from murder (Section 302) to culpable homicide (Section 304 Part-II), reasoning there was no premeditation. The Supreme Court reversed this, holding that when a sharp-edged weapon is used to strike a vital part of the body with force causing fractures to the skull and death, the injury demonstrates knowledge that such force was so dangerous as to probably cause death, establishing murder. Multiple eyewitnesses consistently testified; the respondent was attempting a second blow when stopped. The Court emphasized that absence of premeditation alone does not place an act within Exception 4 when a deadly weapon is used on vital parts. Murder conviction was restored.

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Criminal Law Murder vs. Culpable Homicide Homicide Section 302 IPC Section 304 IPC Exceptions to Section 300 Evidence - Eyewitness Testimony Criminal Procedure

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