A) ABSTRACT / HEADNOTE

Sudam Prabhakar Achat v. The State of Maharashtra (Criminal Appeal No. 641 of 2024; judgment dated 21 March 2025) raises whether a conviction under Section 302, Indian Penal Code, 1860 should be converted to a lesser offence under Section 304 (Part I or II), IPC.

The prosecution case based on ocular testimony of relatives and corroborative medical evidence found that a sudden quarrel over the use of a shared bundh (boundary) escalated when the appellant and his co-accused attacked the deceased; the latter succumbed to injuries the same night.

The courts below convicted the appellant under ss.302/34 and 324/34 IPC; the High Court affirmed. Before the Supreme Court the principal contentions were:

(i) that the testimony of interested, related witnesses is unreliable, and

(ii) that the facts do not disclose murder but at most culpable homicide not amounting to murder.

The Court accepted:

(i) that relatives’ evidence must be scrutinized with circumspection but not discarded merely for relationship, and

(ii) that the assault arose in a sudden quarrel, with weapons being a stick and the blunt side of an axe tools readily available in agricultural fields and that the injuries and manner of assault did not indicate premeditation, cruelty or taking undue advantage.

Applying Exception IV to Section 300 IPC, the Court converted the conviction from Section 302 to Section 304 Part I and directed that the appellant be sentenced to time already undergone (having served six years ten months).

The judgment clarifies the approach to interested-witness testimony, the test for premeditation and cruelty, and the scope for altering a murder conviction to culpable homicide where heat of the moment and weapon-type vitiate the existence of murderous intention.

Keywords: Section 302 IPC; Section 304 Part I IPC; Exception IV to Section 300 IPC; interested witnesses; sudden quarrel; premeditation; homicidal death; related witnesses.

B) CASE DETAILS

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The dispute arose from agrarian neighbours whose fields and well were contiguous. A quarrel on 15 July 2009 about use of a common bundh escalated when the appellant and his co-accused confronted the deceased and his son. According to prosecution witnesses (all relatives of the deceased), the co-accused used an axe (later alleged to be used by its blunt side) and the appellant used a stick to assault the deceased and the complainant.

Both injured men were taken to hospital; the deceased died the same night and criminal proceedings were expanded to include s.302 IPC. Investigation produced inquest panchnama, seizure of clothes, recovery of weapons and statements under s.164 CrPC. The trial court convicted both accused under ss.302/34 and 324/34 and imposed life for murder alongside concurrent terms for grievous hurt.

The High Court dismissed the criminal appeal. Before the Supreme Court the narrow question admitted for consideration was whether the evidence principally the testimony of related eyewitnesses and the nature of the weapons and injuries justified the charge of murder, or whether the conviction should be altered to culpable homicide not amounting to murder (i.e., s.304 Part I or II).

The Supreme Court framed its analysis around the reliability of interested witnesses, the factual matrix of a sudden quarrel occurring close to the accused’s house, the nature of weapons used, the pattern of injuries recorded in post-mortem, and whether there was premeditation, cruelty or knowledge that would attract s.302 IPC rather than s.304.

D) FACTS OF THE CASE

Motiram Deoram Achat (deceased) and Prabhakar Deoram Achat (co-accused) were brothers; their sons (the appellant Sudam and the complainant Bapu) were first cousins. Fields adjoined with a shared well and bundh. On 15 July 2009 the appellant allegedly abused the complainant over pump/well usage; the complainant informed his parents and they confronted the appellant at about noon in the field.

A quarrel ensued; the co-accused reached with an axe and the appellant with a stick. Eye witnesses working nearby all relatives including Chhagan Krishna Achat (PW-1) and the complainant’s mother Sojabai (PW-7) stated that the co-accused struck with the blunt side of the axe while the appellant struck with the stick.

Both the deceased and the complainant sustained injuries. They were taken to Government Hospital, Malegaon and later Dhule; the deceased died the same night, and the complainant died a month later. The police prepared spot and inquest panchnamas, seized clothes and weapons, recorded statements under s.164 CrPC, and filed charges initially under ss.323, 326, 504, 506/34; after death s.302 was added.

At trial prosecution led eight witnesses and nine documents; the accused led no defence witnesses and denied guilt, claiming the deceased slipped. The trial court convicted; the High Court affirmed; this appeal followed with leave focusing on conversion of the conviction.

E) LEGAL ISSUES RAISED

i. Whether conviction under Section 302 IPC is sustainable on the evidence, particularly where principal eyewitnesses are related to the deceased?
ii. Whether the facts disclose premeditation, cruelty or an intention to cause death necessary for s.302 IPC, or whether the offence falls within s.304 Part I/II IPC?
iii. Whether the testimony of interested/related witnesses must be discarded or only scrutinized with circumspection?
iv. If s.302 is unsustainable, whether alteration of conviction to s.304 Part I is appropriate and what sentence should follow.

F) PETITIONER / APPELLANT’S ARGUMENTS

The counsels for the appellant submitted that:
i. Principal prosecution witnesses are relatives and therefore interested witnesses whose testimony cannot be relied upon without independent corroboration.
ii. The incident was a sudden quarrel arising from an agricultural boundary dispute; there was no pre-meditated intention to kill.
iii. Weapons used (a stick, blunt side of an axe) and nature of injuries do not demonstrate brutality or calculated cruelty; therefore s.302 IPC cannot be sustained and conviction must be converted to s.304 (Part I or II) IPC.
iv. The appellant has already undergone substantial sentence (6 years 10 months) and thus no further custodial order is warranted if conversion is ordered.

G) RESPONDENT’S ARGUMENTS

The counsels for the State submitted that:
i. Concurrent findings of fact by trial court and High Court that accused caused the homicidal injuries merit no interference.
ii. Post-mortem and medical evidence establish homicidal death and link injuries to the accused; interested witness status alone cannot impeach consistent ocular testimony.
iii. The nature and multiplicity of injuries and the sequence of events justify conviction under s.302 rather than conversion.

H) RELATED LEGAL PROVISIONS

i. Section 300 IPC — definition of murder; Exception IV — culpable homicide not amounting to murder where there is grave and sudden provocation and no premeditation.
ii. Section 302 IPC — punishment for murder.
iii. Section 304 IPC (Part I & II) — culpable homicide not amounting to murder — punishment where there is knowledge that act is likely to cause death (Part I) or where act is done with intention to cause bodily injury likely to cause death but without intention to cause death (Part II).
iv. Section 164 CrPC — recording of statements by a Magistrate.
(All provisions as considered in the judgment.)

I) JUDGEMENT

The Court affirmed that the death was homicidal and that the appellant and co-accused caused the fatal injuries. It accepted that witnesses were related but reiterated the settled rule that relationship does not automatically discredit testimony; rather, such evidence must be tested with greater caution and circumspection.

The evidence of PW-1 and other relatives placed the scene near the accused’s house, supported the sequence of assault and weapon use, and was consistent with hospital records and post-mortem findings. The Court examined weapon typology and dynamics: one assailant allegedly used a stick, the other the blunt side of an axe.

The Court reasoned that if the assailants intended to kill they would more likely have used the sharp side of the axe; the choice and nature of assault suggested a sudden fracas rather than deliberate killing. The medical evidence and the pattern of injuries did not indicate extreme cruelty, prolonged or calculated attack, or other features of mala fide intention to kill.

On these factual matrices the Court concluded that the elements of murder under s.300 IPC were not fully established against the appellant; Exception IV to s.300 was attracted because the assault arose from sudden provocation and lack of premeditation. Thus, the conviction under s.302 IPC was converted to s.304 Part I IPC.

Having regard to sentence already undergone (6 years 10 months), the Court ordered no further punishment and directed release if not wanted in other cases. The appeal was accordingly partly allowed.

a. RATIO DECIDENDI

The decisive reasoning is twofold:

(1) the credibility of related witnesses may sustain conviction if their evidence is credible, consistent and corroborated by medical and circumstantial material; and

(2) where an assault arises in the heat of the moment with weapons that do not reflect a deliberate plan to kill, and where medical evidence does not demonstrate excessive cruelty, the ingredients of murder under s.300 IPC may be absent and the conviction can properly be reduced to culpable homicide not amounting to murder (here s.304 Part I) under Exception IV to s.300.

This legal approach emphasizes close analysis of mens rea, weapon used and the immediacy of provocation.

b. OBITER DICTA 

The Court observed (in dicta) that tools commonly present in agricultural fields (sticks, axes) frequently feature in rural offences and their availability alone does not indicate preplanning. It further noted that the conduct of co-accused (using blunt rather than sharp edge) and appellant (use of stick) pointed away from calculated killing an observation useful in assessing intention in similar rural, provocation-driven confrontations. The Court reiterated that concurrent findings of fact deserve weight but are not immune from reassessment when legal classification of offence (murder vs. culpable homicide) is at issue.

c. GUIDELINES 

i. Testimony of related/interested witnesses may be acted upon, but must be scrutinized with greater circumspection and evaluated alongside independent material (medical reports, recoveries, panchnamas, s.164 statements).

ii. For conversion from s.302 to s.304, courts must examine

(a) presence or absence of premeditation;

(b) nature of weapon and manner of use;

(c) whether assault occurred in heat of passion arising from grave and sudden provocation;

(d) medical evidence on nature and gravity of injuries to see if cruelty/undue advantage is indicated.

iii. If the facts reasonably permit inference of sudden quarrel without murderous intention, Exception IV of s.300 and s.304 Part I provide appropriate statutory classification and sentencing flexibility.

iv. Where accused have already undergone substantive custodial sentence and conversion is ordered, courts should factor time served in resentencing to avoid double punishment.

J) CONCLUSION & COMMENTS

The decision carefully balances evidentiary principles with substantive criminal law. It affirms that interested witnesses, if consistent and corroborated, can furnish reliable proof of culpability; but it also underscores that the categorical move from homicidal act to murder requires positive indicia of premeditation, extreme cruelty or grave knowledge of fatal consequences.

The Court’s conversion to s.304 Part I underscores judicial restraint in mete out the gravest label of murder where the proved facts more comfortably fit culpable homicide arising from sudden provocation. Practitioners should note the emphasis on weapon-analysis and context in determining mens rea and the Court’s readiness to alter conviction classification where the evidence so warrants.

The sentencing outcome credit for time served reflects proportionality in penal consequences after conversion. This judgment will guide trial and appellate courts in rural assault cases where family relationships, agricultural implements and sudden quarrels form the recurring fact pattern.

K) REFERENCES

1. Sudam Prabhakar Achat v. The State of Maharashtra, Criminal Appeal No. 641 of 2024, Supreme Court of India, judgment dated 21 March 2025, [2025] 3 S.C.R. 897; 2025 INSC 378.

2. Indian Penal Code, 1860 (India), s.300 (Exception IV), s.302, s.304 (Part I & II).

3. Code of Criminal Procedure, 1973 (India), s.164 (recording of statements).