Chhattisgarh HC Alters Murder Conviction to Culpable Homicide, Cites 'Sudden Fight' Exception Under S.300 IPC - 2025-04-03

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Chhattisgarh High Court Reduces Murder Sentence to 10 Years in Culpable Homicide Case

Bilaspur, Chhattisgarh – In a significant judgment delivered on March 5, 2025, a division bench of the Chhattisgarh High Court, comprising Chief Justice Ramesh Sinha and Justice Ravindra Kumar Agrawal , has partly allowed a criminal appeal, altering a trial court's conviction from murder under Section 302 of the Indian Penal Code (IPC) to culpable homicide not amounting to murder under Section 304 Part-I IPC. The case, CRA No. 690 of 2021, Chaitram Rathiya @ Khunda v. State Of Chhattisgarh , saw the court reduce the life imprisonment sentence of the appellant, Chaitram Rathiya , to 10 years of rigorous imprisonment.

Case Background: The Fatal Blow

The case originated from an incident on October 3, 2018, in Aamgaon village, Raigarh district, where Chaitram Rathiya was accused of fatally attacking Mohit Ram with a 'tangia' (axe). The prosecution’s case rested on the testimony of eyewitness Geeta Sidar (daughter-in-law of the deceased), and circumstantial evidence including seizure of the weapon and blood-stained clothes. The trial court in Gharghoda had convicted Rathiya under Sections 302 (murder) and 452 (house-trespass to cause hurt) IPC on February 25, 2021, sentencing him to life imprisonment and 5 years rigorous imprisonment respectively, with both sentences running concurrently.

Appellant's Arguments: Lack of Motive and Weak Evidence

Appearing for the appellant, Advocate Savita Tiwari argued that the trial court erred in convicting Rathiya for murder. She contended that the prosecution failed to establish any motive for the crime and that the case relied on weak circumstantial evidence. Tiwari highlighted contradictions in the eyewitness testimony and argued that the conviction was based on the statements of 'interested witnesses'. She asserted that the prosecution had not presented "cogent & reliable evidence" to prove murder and sought to quash the trial court's judgment.

State's Stand: Upholding the Murder Conviction

Representing the State, Panel Lawyer Swajeet Ubeja defended the trial court's judgment. He argued that Rathiya had caused Mohit Ram 's death by a deadly attack with a 'tangia', leading to fatal injuries. Ubeja maintained that the trial court rightly convicted Rathiya under Section 302 and 452 IPC and that the case did not warrant conversion to culpable homicide under Section 304 IPC.

High Court's Analysis: Exception 4 to Section 300 IPC

The High Court, after reviewing the evidence and arguments, focused on whether the case fell under Exception 4 to Section 300 IPC, which deals with culpable homicide not amounting to murder in cases of sudden fights without premeditation in the heat of passion.

The court noted the eyewitness testimony of Geeta Sidar (PW-3) who stated that the accused came to the house, inquired about others, and then attacked Mohit Ram . The court also considered the medical evidence from Dr. Dhansingh Pankra (PW-8), who conducted the postmortem and confirmed the homicidal nature of death due to cut wounds and excessive bleeding.

Referencing several Supreme Court judgments including Sukhbir Singh v. State of Haryana , Arjun v. State of Chhattisgarh , and Anbazhagan vs. The State , the High Court elaborated on the legal principles distinguishing murder from culpable homicide and the applicability of Exception 4.

The judgment quoted key principles from Anbazhagan vs. The State , emphasizing that:

> "To put it more succinctly, the difference between the two parts of Section 304 of the IPC is that under the first part, the crime of murder is first established and the accused is then given the benefit of one of the exceptions to Section 300 of the IPC, while under the second part, the crime of murder is never established at all."

Applying these principles to the present case, the High Court concluded:

> "Thus with the intention to cause death of deceased, the appellant caused such injuries and by doing so, he must have had the knowledge that such injuries inflicted by him would likely cause death of the deceased, as such, his case would falls within the purview of Exception 4 of Section 300 of IPC, as the act of appellant herein completely satisfies the four necessary ingredients of Exception 4 to Section 300 IPC i.e. (i) there must be a sudden fight; (ii) there was no premeditation; (iii) the act was committed in a heat of passion and (iv) the appellant had not taken any undue advantage or acted in a cruel or unusual manner."

Final Verdict: Conviction Altered, Sentence Reduced

Based on this analysis, the High Court set aside the conviction under Section 302 IPC, convicting Chaitram Rathiya instead under Section 304 Part-I IPC (culpable homicide not amounting to murder). The life imprisonment sentence was reduced to 10 years of rigorous imprisonment, while the sentence under Section 452 IPC remained unchanged.

The court directed the registry to inform the appellant of his right to appeal to the Supreme Court, providing access to legal aid if needed. This judgment highlights the nuanced application of Exception 4 to Section 300 IPC and its impact on sentencing in homicide cases, offering a significant legal precedent within the Chhattisgarh jurisdiction.