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Supreme Court Rules Killing During Heated Verbal Quarrel Not Classified as Murder

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Published on: December 04, 2023 at 16:20 IST

The Supreme Court overturned the murder conviction of an accused, stating that the act of killing occurred during a fit of anger in the midst of a passionate verbal quarrel.

The court invoked Exception 4 of Section 300 of the Indian Penal Code (IPC) and instead convicted the individual for culpable homicide not amounting to murder.

The bench, comprising Justice Vikram Nath and Justice Rajesh Bindal, concluded that the clear intent required to prove culpable homicide amounting to murder had not been established by the prosecution.

The accused had been convicted of culpable homicide in the murder of Kolandaippam, stemming from a longstanding enmity over a land dispute. During a confrontation, the appellant and another individual stabbed the deceased multiple times with poor knives.

The trial court had initially convicted them under Section 302 of the IPC, sentencing them to life imprisonment.

The High Court upheld the decision. However, the Supreme Court, upon reviewing the evidence, facts, and circumstances, concluded that the wound inflicted by the appellant was the direct cause of the deceased person’s death.

The court framed the key issue of determining whether the act constituted culpable homicide amounting to murder or fell under Exception 4 to Section 300 of the IPC.

Citing the case of Rampal Singh v State of UP, the court highlighted the distinction between the two categories, emphasizing that the classification depends on the evidence presented during the trial.

In this case, the court noted that the stabbing occurred abruptly during a heated verbal argument, rather than a preplanned attack with the intent to cause death.

The appellant’s actions were deemed impulsive, happening suddenly in the heat of passion, without a premeditated intention to kill.

As a result, the Supreme Court partially allowed the appeal and modified the punishment to 10 years of Rigorous Imprisonment. The case is titled Mariappan v State Rep. By Inspector Of Police (2023 INSC 1034).