The Supreme Court on Wednesday strongly criticised the Chhattisgarh High Court for reducing a man's conviction from murder to culpable homicide not amounting to murder, observing that the High Court appeared to have overlooked fundamental principles of criminal law and important circumstances surrounding the crime.

A Bench of Justice J.B. Pardiwala and Justice K. Vinod Chandran made the observations while hearing a challenge to the High Court's November 2024 judgment, which had reduced the accused's conviction from Section 302 of the Indian Penal Code (IPC) to Section 304 Part II IPC and reduced his sentence from life imprisonment to 10 years.

“Just see the pathetic condition of the High Court. The judges don’t know what is Section 304 Part I and Section 304 Part II of the IPC! And you expect the judges to appreciate the evidence!” the Bench remarked.

The Court further observed that it was not the first time it had encountered such a judgment, adding that these principles were taught in the first year of law school.

Supreme Court Questions High Court's Understanding of Criminal Law

The case concerns the death of a woman who was assaulted in February 2021. According to the prosecution, the accused visited the woman's house looking for her son. The woman was subsequently found lying in a pool of blood.

Before her death, she reportedly told her husband that the accused had assaulted her. The post-mortem examination revealed injuries to her head and face and attributed her death to a head injury.

In September 2022, the trial court convicted the accused of murder under Section 302 IPC and sentenced him to life imprisonment.

However, in November 2024, a Division Bench of the Chhattisgarh High Court comprising then Chief Justice Ramesh Sinha and Justice Rajani Dubey altered the conviction to Section 304 Part II IPC and reduced the sentence to 10 years.

The High Court had reasoned that the assault occurred during a sudden quarrel and that the accused did not intend to kill the woman.

Court Highlights Difference Between Section 304 Part I and Part II IPC

The Supreme Court expressed concern over the High Court's decision to alter the conviction without properly examining the relevant legal principles and circumstances.

Section 304 Part I IPC applies to culpable homicide not amounting to murder where the act is committed with the intention of causing death or bodily injury likely to cause death. Section 304 Part II IPC applies where the accused has knowledge that the act is likely to cause death but lacks the intention contemplated under Part I.

The distinction is significant because the intention and knowledge attributable to an accused, along with the nature of the injuries and the circumstances of the incident, determine the appropriate offence.

The Bench observed that the High Court had altered the conviction in a “slipshod manner” and appeared to have overlooked the nature of the injuries, the weapons used and the genesis of the occurrence.

“The High Court as usual in a very slipshod manner and without any understanding of law partly allowed the appeal by altering the conviction from Section 302 to Section 304 Part II of IPC,” the Court observed.

Supreme Court Issues Notice on Restoration of Murder Conviction

Taking note of the issues raised, the Supreme Court issued notice calling upon the accused to explain why the High Court's judgment should not be set aside and the trial court's conviction for murder restored.

The Bench stated that it would reconsider the matter on its merits after examining the relevant circumstances. It also sought a response from the State of Chhattisgarh.

The proceedings will determine whether the High Court's decision to reduce the conviction from murder to culpable homicide not amounting to murder can be sustained.