Supreme Court Clarifies Murder vs. Attempt to Murder in Delayed Death: Key Takeaways from Maniklal Sahu vs. State of Chhattisgarh
Criminal Appeal No. 5578 of 2024, Judgment Dated September 12, 2025
In a landmark judgment, the Supreme Court has clarified the distinction between murder under Section 302 and attempt to murder under Section 307 of the Indian Penal Code (IPC), specifically in cases where the death occurs long after the original assault due to medical complications like septicemia. The ruling came from the recent Maniklal Sahu v. State of Chhattisgarh case, which sheds new light on how courts should treat delayed deaths caused by the injuries inflicted in an assault.
Key Facts:
The case involved the conviction of Maniklal Sahu and three co-accused for the murder of Rekhchand Verma. Rekhchand was assaulted by the accused on February 22, 2022, and suffered severe injuries. He survived for about nine months but eventually died on November 8, 2022, due to septicemia and pneumonia, complications arising from the original injuries.
Initially, the accused were convicted under Section 302 (murder) of the IPC. However, the Chhattisgarh High Court later altered the conviction to attempt to murder under Section 307, arguing that the death resulted from the lack of proper treatment and not directly from the assault. This judgment was appealed to the Supreme Court, which delivered a landmark ruling.
Supreme Court’s Ruling:
The Supreme Court overruled the High Court’s decision, clarifying that even when death is delayed due to complications like septicemia, if the original injuries were sufficient in the ordinary course of nature to cause death, the offense should remain classified as murder under Section 302 of the IPC. The court emphasized that the cause of death, even if delayed by complications, remains linked to the original assault if the injuries were severe enough to cause death in normal circumstances.
Key Highlights:
Delayed Death & Causation:
The Court clarified that if the original injuries were sufficient to cause death in the ordinary course of nature, the fact that death occurred later due to complications does not alter the charge from murder to attempt to murder.
Supervening Causes:
The Court highlighted that the presence of a supervening cause (like septicemia) will not sever the causal link between the assault and the death unless the injuries healed and the fatal complications were unforeseen. If the complications were a natural consequence of the injury, it is still considered murder.
Evidence & Medical Testimony:
The Court strongly disagreed with the High Court’s assumption that lack of treatment caused the death, pointing out the absence of evidence to support that claim. The testimony from medical professionals confirmed that the injuries were severe enough to be deemed sufficient to cause death.
Intention & Knowledge:
The Court also affirmed that if the injuries inflicted were intended to cause death, it would still be classified as murder under Section 302, even if death occurred after complications from the injury.
Clarity on Section 300:
The Court reinforced that death caused by injuries that are sufficient to cause death falls under the third limb of Section 300 of the IPC, making it a case of murder, not attempted murder.
Practical Implications for Courts:
This ruling is significant for the judiciary as it offers comprehensive guidelines on handling cases involving delayed deaths due to medical complications. Courts will need to:
Determine whether the injuries were sufficient to cause death in ordinary circumstances.
Assess if the complications are directly linked to the injuries inflicted.
Establish whether the original injuries were likely to cause death, regardless of medical treatment or unforeseen complications.
Conclusion:
The Supreme Court’s judgment in Maniklal Sahu v. State of Chhattisgarh reinforces the principle of causation in criminal law and affirms that delayed deaths due to complications still fall under the ambit of murder, as long as the injuries were sufficient to cause death in the ordinary course of nature. This ruling will guide future cases involving similar circumstances, ensuring that justice is served accurately and consistently.
Need Legal Assistance?
If you need expert legal advice for criminal cases, bail matters, divorce case, maintenance case, or domestic violence case, NRI Divorce case other family disputes like Civil or partition cases, get in touch today!
📍 Office: 137, J-Extension, Laxmi Nagar, Delhi, 110092
📞 Contact: 8595722509
Advocate Devashish Maharishi
Best Divorce Case Lawyer in Karkardooma Court, Delhi
Divorce Lawyer in Saket Court, South Delhi
Contested Divorce Lawyer in Saket Court
Mutual Consent Divorce Lawyer in Saket Court
Domestic Violence Lawyer in Saket Court
Maintenance and Alimony Lawyer in Saket Court
Family Dispute Lawyer in Saket Court
NRI Divorce Lawyer in Saket Court
Transfer Petition Lawyer in Saket Court
Comments
Post a Comment