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2025 Supreme(SC) 1677

J. B. PARDIWALA, R. MAHADEVAN
Maniklal Sahu – Appellant
Versus
State of Chhattisgarh – Respondent


Advocates appeared:
For the Appellant(s) : Mr. Padmesh Mishra, Adv. Ms. Vastvikta Bhardwaj, Adv. Ms. Neelam Singh, AOR Mr. Vijant, Adv.
For the Respondent(s): Mrs. Prerna Dhall, Adv. Mr. Shivam Ganeshia, Adv. Ms. Akanksha Singh, Adv. Mr. Ambuj Swaroop, Adv. Mr. Kapil Katare, Adv. Mr. Prashant Singh, AOR Ms. Rajnandani Kumari, Adv.

Judgement Key Points

Key Points: - The most important ingredient to constitute the offence of attempt to commit murder under Section 307 of the IPC is the intention or knowledge of the accused to cause death (!) (!) . - The theory of causation must be kept within reasonable limits, and if death is delayed due to natural or probable complications flowing from the injury, the original injury is still considered the cause of death (!) (!) . - The Supreme Court dismissed the appeal, holding that the High Court committed a serious error in downgrading the conviction from murder (Section 302) to attempt to commit murder (Section 307) solely because the victim died after nine months due to complications (!) (!) . - Even if death results from complications like septicemia or pneumonia arising from the original injury, the accused is liable for murder if the injuries were sufficient in the ordinary course of nature to cause death (!) (!) . - It is not essential for a conviction under Section 307 that the act inflicted a bodily injury capable of causing death, but the act must be done with the intention or knowledge that it would cause death if it took effect (!) (!) . - The possibility that skilful and efficient medical treatment might have prevented the fatal result is wholly irrelevant in determining the nature of the offence (!) . - If the supervening causes are attributable to the injuries caused by the accused, the person inflicting the injuries is liable for causing death even if death was not the direct result (!) . - The court clarified that if the chain of consequences is broken by an unexpected complication causing a new mischief, the causal connection is too remote to establish liability for the original injury (!) . - Intention is a state of mind that cannot be proved by direct evidence but can be inferred from circumstantial evidence such as the nature of the weapon, manner of use, and nature of injuries (!) . - The Supreme Court held that the injuries suffered by the deceased were sufficient in the ordinary course of nature to cause death and fell under clause "Thirdly" of Section 300 of the IPC (!) .

What are the essential ingredients to constitute the offence of attempt to commit murder under Section 307 of the IPC?

What is the application of the theory of causation where death ensues after some delay due to complications?

What are the rights of the accused regarding the distinction between murder and attempt to commit murder when death occurs after a long interval due to supervening causes?


Table of Content
1. facts of the case leading to the appeal. (Para 1 , 2 , 3 , 4 , 5 , 6 , 7)
2. arguments against conviction under section 307 ipc. (Para 8 , 9)
3. state's position regarding conviction. (Para 10 , 11)
4. court's assessment of the high court's findings. (Para 12 , 13 , 14)
5. overview of the medical evidence presented. (Para 15 , 16 , 17)
6. determination of causation related to death. (Para 18 , 19 , 21)
7. legal interpretation of sections 299, 300, and 307 ipc. (Para 22 , 23)
8. clarification on interpreting deaths following injuries. (Para 24 , 25 , 26)
9. explanation of attempt to murder under section 307 ipc. (Para 27 , 28 , 29)
10. further clarification on the meaning of intention. (Para 30 , 31 , 32 , 33 , 34 , 35)
11. assessment of causation regarding medical treatment. (Para 36 , 37 , 38 , 39 , 40)
12. implications of medical complications on culpability. (Para 41 , 42 , 43 , 44 , 45)
13. summary on proximate and remote causes. (Para 46 , 47 , 48)
14. clarification on situational nuances impacting culpability. (Para 49 , 50 , 51 , 52 , 53 , 54)
15. judicial interpretation of contributory causes of death. (Para 55 , 56 , 57 , 58 , 59)
16. final determination of judgment ba

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