This Supreme Court judgment clarifies that a time gap between the infliction of an injury and death does not automatically reduce the offence from murder to attempt to murder. If the original injury was sufficient in the ordinary course of nature to cause death, subsequent complications like septicemia do not break the chain of causation. The offence remains punishable under Section 302 IPC, rendering Section 307 inapplicable.
Facts Of The Case:
The case originated from a violent incident on February 22, 2022, in which the appellant, Maniklal Sahu, along with three co-accused, trespassed into the house of Rekhchand Verma. They dragged the victim to the terrace of his house and flung him down. After the fall, the accused further assaulted the injured Rekhchand with sticks and fists. The victim was rushed to the hospital in a critical condition, where his dying declaration was recorded, naming the assailants. Despite medical treatment, Rekhchand Verma survived for approximately nine months in a severely debilitated state, ultimately succumbing to his injuries on November 8, 2022. The cause of death was certified as septic shock with bilateral pneumonia, stemming from post-traumatic spinal cord injury with paraplegia and infected bedsores. The Trial Court convicted the accused for murder under Section 302 of the IPC. On appeal, the High Court altered the conviction to Section 307 (attempt to murder), primarily citing the nine-month interval between the assault and the death, and speculating a lack of proper treatment. This reduction of the conviction by the High Court was subsequently challenged before the Supreme Court.
Procedural History:
The case commenced with the conviction of Maniklal Sahu and his co-accused for murder under Section 302 of the Indian Penal Code by the Trial Court. Aggrieved by this conviction, the appellant filed Criminal Appeal No. 607 of 2023 before the High Court of Chhattisgarh. In its judgment dated July 30, 2024, the High Court partly allowed the appeal by altering the conviction from Section 302 IPC to one of attempt to murder under Section 307 IPC, sentencing the appellant to seven years of rigorous imprisonment. The appellant then challenged this High Court verdict before the Supreme Court of India by way of the present Criminal Appeal No. 5578 of 2024, which ultimately culminated in the judgment rendered on September 12, 2025.
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Court Observation:
The Supreme Court strongly disapproved of the High Court’s reasoning, observing that the mere survival of a victim for a prolonged period (nine months in this case) does not, by itself, downgrade the offence from murder to an attempt to murder. The Court emphasized that the crucial legal test is whether the injuries inflicted were sufficient in the ordinary course of nature to cause death, which in this case, the spinal cord injury was. It held that subsequent complications like septicemia and pneumonia were a direct and natural consequence of the original, life-threatening injuries and did not break the chain of causation. The Court further clarified that the adequacy of medical treatment is irrelevant, as per Explanation 2 to Section 299 of the IPC, and found no evidence to support the High Court’s speculation about a “lack of proper treatment.” Consequently, it concluded that the case squarely fell under the “thirdly” clause of Section 300, making it murder punishable under Section 302 IPC, and the High Court committed a grave error in applying Section 307.
Final Decision & Judgement:
The Supreme Court, in its final judgment, dismissed the appeal filed by the convict, Maniklal Sahu. While the Court expressly disagreed with the High Court’s legal reasoning and found that the offence conclusively amounted to murder under Section 302 of the IPC, it could not reinstate the murder conviction. This was because the State had not filed a cross-appeal against the High Court’s order that had reduced the conviction to Section 307. Therefore, the practical outcome is that the appellant’s conviction under Section 307 IPC and the sentence of seven years’ rigorous imprisonment imposed by the High Court were upheld, but the Supreme Court’s extensive observations serve as a binding precedent on the legal principles of causation and the application of Section 302 IPC in cases of delayed death.
Case Details:
Case Title: Maniklal Sahu vs State of Chhattisgarh Citation: 2025 INSC 1107 Criminal Appeal No: Criminal Appeal No. 5578 of 2024 Date of Judgement: 12th September, 2025 Judges/Justice Name: Justice J.B. Pardiwala and Justice R. Mahadevan
Download The Judgement Here