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Supreme Court of India 2019-04-10 allowed

The State of Rajasthan vs Kanhaiya Lal

Bench: 2 — L. Nageswara Rao, M.R. Shah

In Brief

The State challenged a High Court decision that had downgraded the accused's conviction from murder (Section 302, IPC) to culpable homicide (Section 304 Part I). The High Court had relied on the fact that only a single blow was struck and there had been an altercation hours earlier. The Supreme Court held that a single blow with a deadly weapon (an axe) on a vital body part (the head) is sufficient for murder conviction if it exhibits intention to cause death. The nature of weapon, location, and fatal injury prove intent. An earlier quarrel cannot negate intention when the actual attack was unprovoked. The Court allowed the appeal and restored the murder conviction.

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Criminal Law Murder Culpable Homicide Intention Indian Penal Code

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