The Supreme Court upheld the concurrent findings of the courts below on the appellants’ involvement in causing the deaths. However, it altered the conviction from Section 302 IPC to Section 304 Part I IPC, finding that the act was done with the knowledge that it was likely to cause death, but without the intention to kill. The sentence already undergone was deemed sufficient.
Facts Of The Case:
On the morning of August 6, 1986, complainant Ram Gopal (PW-1) went with his father and two uncles to a river ghat to measure agricultural land for partition. There, they encountered the four accused appellants, including the owner of the adjacent land, Raghav Prashad. The accused, who were hiding, suddenly emerged and a dispute over the measurement ensued. This altercation quickly turned violent, with the accused attacking the complainant’s group with weapons including sticks, a pike, and a spear. The injured parties were taken to the police station, where an FIR was registered. They were subsequently hospitalized, but all three—Ram Antar, Namo Shankar, and Girija Shankar—succumbed to their injuries the same day. The charges were consequently upgraded to murder. The prosecution’s case rested primarily on the eyewitness testimony of PW-1. The trial court and later the High Court convicted the appellants under Section 302 read with Section 34 of the Indian Penal Code and sentenced them to life imprisonment, leading to the present appeal before the Supreme Court.
Procedural History:
The procedural history of the case began with the conviction of the accused appellants by the Additional District and Sessions Judge, Karvi, on 8th November 1989, for the offence punishable under Section 302 read with Section 34 of the Indian Penal Code, sentencing them to rigorous imprisonment for life. Aggrieved by this decision, the appellants filed Criminal Appeal No. 2259 of 1989 before the High Court of Judicature at Allahabad. The High Court, vide its judgment dated 4th July 2013, dismissed the appeal and upheld the conviction and sentence ordered by the trial court. Subsequently, the appellants approached the Supreme Court by way of special leave, which culminated in Criminal Appeal No. 596 of 2014, leading to the present judgment.
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Court Observation:
In its observations, the Supreme Court affirmed the concurrent findings of the Trial Court and the High Court that the accused appellants were responsible for causing the deaths of the three deceased persons, based on the reliable testimony of the sole eyewitness (PW-1). However, the Court crucially distinguished between intention and knowledge, noting that while the accused had the knowledge that their actions were likely to cause death, the evidence—specifically the use of the blunt sides of weapons and the resulting lacerated wounds—did not establish an intention to kill. Consequently, the Court held that the offence did not amount to murder under Section 302 IPC but was culpable homicide not amounting to murder, punishable under Section 304 Part I of the Indian Penal Code.
Final Decision & Judgement:
The Supreme Court partly allowed the appeal. It set aside the conviction of the accused appellants under Section 302 of the Indian Penal Code and instead convicted them under the lesser offence of Section 304 Part I. Regarding the sentence, the Court found that the period of over 12 years of imprisonment already undergone by the appellants was sufficient to serve the interests of justice for the modified conviction. Consequently, the Court directed that the appellants be released forthwith, provided they are not required in any other case.
Case Details:
Case Title: Raghav Prashad and Others vs. State of U.P. Citation: 2025 INSC 1172 Criminal Appeal No.: Criminal Appeal No. 596 of 2014 Date of Judgement: September 26, 2025 Judges/Justice Name: Justice B.R. Gavai & Justice K. Vinod Chandran
Download The Judgement Here