The Supreme Court stated that simply knowing the outcome of deadly actions is sufficient to hold a murder suspect responsible.

The Supreme Court, in a murder case, stated that simply knowing the outcome of harmful actions is enough to hold the accused responsible. This was noted in a Criminal Appeal against the conviction of the accused under Sections 302, 324, 326, and 34 of the Indian Penal Code (IPC). The two-Judge Bench, consisting of Justice Vikram Nath and Justice Prasanna B. Varale, remarked, “The intentional act of stabbing critical areas of the body, along with the force applied, shows that the appellant must have understood the potential fatal results of his actions. According to Section 300 IPC, intending to inflict injuries that could naturally lead to death is considered murder. Even if other factors besides the intention to kill are present, just having knowledge of the fatal outcome is sufficient to hold the accused accountable.”

The Bench added that even if we assume the accused did not intend to cause injury, using a knife on vital areas indicates an awareness that such actions could likely result in death. Senior Advocate Nikhil Goel represented the Appellant/accused, while Senior Advocate P.V. Dinesh represented the Respondent/State.

In 2006, supporters of the United Democratic Front (UDF) and the Left Democratic Front (LDF) clashed over a dispute about their election symbol near a library in Kunnappalli, Pathaikkara Village. A criminal case with serious charges was filed against UDF supporters related to this incident. The Appellant, along with others from the Indian Union Muslim League (IUML), waited at Mukkilaplavu Junction to confront the deceased due to ongoing hostility. At around 8:45 PM, when the deceased and another person arrived, the first accused allegedly tried to hit the deceased with a tamarind stick.

The deceased defended himself, took the stick, and struck the first accused on the forehead and back. In response, the first accused pulled out a knife and stabbed the deceased in the chest, back of the head, and left shoulder. Another individual was also hurt during this altercation. A case was filed against the accused, and the Trial Court found the Appellant guilty of murder. Three appeals were made to the High Court, but they were all rejected. The Supreme Court observed that carrying and using a weapon during the fight showed a willingness to escalate violence beyond a simple fight. Even if the Appellant did not plan to kill the deceased beforehand, the injuries inflicted were enough to likely cause death.

The Court noted that the defense’s claim that the incident was just a spontaneous fight does not free the Appellant from responsibility. Although the fight may have led to the attack, the Appellant’s use of a deadly weapon and the way the injuries were caused change the act from culpable homicide to murder. The Court emphasized that intent can be determined by the type and severity of injuries, the weapon used, and how it was used. Using a deadly weapon and intentionally targeting vital areas of the body strongly suggest intent.

Additionally, the Court clarified that to classify the Appellant’s actions under Section 304 IPC, considering the offense was committed in self-defense but went beyond the legal limits, the necessary elements of Exception 2 to Section 300 IPC must be established. It highlighted the key elements for this exception –

1. The accused should not be responsible for starting the situation.
2. There must be a serious threat to life or severe injury, whether it is real or seems real.
3. The accused suffered injuries.
4. The accused caused injuries to others.
5. The accused had no chance to seek help from the authorities.

The appellant’s claim of acting in self-defense does not change the fact that he played a key role in starting the fight. The Court stated that he cannot take advantage of the self-defense exception when he helped create the situation that led to the conflict. Even if we assume the appellant was defending himself, the evidence clearly shows that the force he used was too much. Stabbing the victim multiple times in critical areas like the chest and heart is far beyond what is allowed in self-defense.

The Court explained that the principle of parity aims to ensure fair sentencing for co-defendants who are in similar situations and share the same level of guilt. However, this principle does not guarantee equal treatment; each person’s role, intent, and actions must be evaluated separately to understand their involvement in the crime. Additionally, the Court noted that a murder aimed at vital organs, especially in a group context, shows a level of intent and brutality that requires a fitting punishment. Reducing the sentence in such cases could undermine the seriousness of the crime and the value of life, which the justice system must protect.

The crime took place amid political rivalry, which makes it more serious. Offenses driven by such motives can lead to significant effects beyond just the loss of life, causing social unrest and diminishing trust in the law. The Court must ensure its rulings support accountability and prevent future violent acts that disturb public order. The Court concluded that once a conviction under Section 302 of the IPC is confirmed by all courts, the minimum punishment is life imprisonment, as stated in the law. Therefore, there is no reason to impose a lesser sentence. It noted that since the minimum sentence is life, factors like equality, leniency, age, or health issues cannot help the accused in seeking a reduced sentence. As a result, the Appellant received the minimum sentence for murder. Consequently, the Apex Court rejected the appeal for a lighter sentence and upheld the conviction.

Cause Title: Kunhimuhammed @ Kunheethu v. The State of Kerala (Neutral Citation: 2024 INSC 937)
Appearance:
Appellant: Senior Advocate Nikhil Goel, AOR Radha Shyam Jena, Advocates Haris Beeran, Azhar Assees, and Anand B. Menon.
Respondent: Senior Advocate P.V. Dinesh, AOR Nishe Rajen Shonker, Advocates Anu K Joy, Alim Anvar, Anna Oommen, and Urvashi Chauhan.