A) ABSTRACT / HEADNOTE

The judgment examines the criminal liability of an accused convicted for causing death during a sudden altercation arising out of prior enmity between two families. The Supreme Court was called upon to determine whether the High Court correctly modified the conviction from murder under Section 302 IPC to culpable homicide not amounting to murder under Section 304 Part II IPC by invoking Exception 4 to Section 300 IPC. The case also raised significant questions concerning the evidentiary value of testimonies of related witnesses, the applicability of the doctrine of parity when co-accused are acquitted, and the scope of the maxim falsus in uno falsus in omnibus under Indian criminal jurisprudence.

The Court reaffirmed that Indian courts do not mechanically discard testimony merely because witnesses are related, nor does acquittal of co-accused automatically entitle the main accused to acquittal. The judgment clarifies that Exception 4 to Section 300 IPC applies when death is caused without premeditation, in a sudden fight, and without cruelty or undue advantage. Upholding the High Court’s reasoning, the Supreme Court emphasized consistency between ocular testimony and medical evidence, and endorsed a cautious yet pragmatic approach to appreciation of evidence. The decision reinforces settled principles governing criminal trials while balancing culpability with factual realities of spontaneous violence.

Keywords:
Culpable homicide; Exception 4 to Section 300 IPC; Related witness testimony; Rule of parity; Falsus in uno falsus in omnibus

B) CASE DETAILS

C) INTRODUCTION AND BACKGROUND OF JUDGMENT

The appeal arose from a judgment of the Madurai Bench of the Madras High Court which partly allowed the appeal of the accused by altering his conviction from Section 302 IPC to Section 304 Part II IPC. The modification was grounded on the finding that the incident occurred during a sudden and free fight, thereby attracting Exception 4 to Section 300 IPC. The case stemmed from a long-standing familial dispute triggered by an alleged illicit relationship, culminating in a violent confrontation resulting in one death and injuries to others.

The Trial Court had convicted the appellant for murder and voluntarily causing hurt by dangerous weapons while acquitting the remaining co-accused due to lack of reliable evidence against them. The High Court concurred with the factual findings but revisited the nature of mens rea and circumstances surrounding the act, concluding that the ingredients of murder were not fully satisfied.

Before the Supreme Court, the appellant challenged the conviction primarily on three grounds: reliance on interested witnesses, denial of parity with acquitted co-accused, and selective acceptance of witness testimony. The Court was thus required to evaluate the evidentiary framework within the boundaries of settled criminal jurisprudence. The judgment situates itself within a line of authorities emphasizing careful scrutiny rather than outright rejection of related witness testimony and rejecting rigid application of evidentiary maxims.

D) FACTS OF THE CASE

The factual matrix reveals pre-existing hostility between two families due to an alleged illicit relationship involving a family member of the complainant and the daughter of one of the accused. On 26 January 2002, the accused persons assembled near the complainant’s house, leading to a sudden confrontation. During this altercation, the appellant assaulted the complainant with an iron rod, causing injuries substantiated by medical evidence.

The deceased, upon hearing the commotion, intervened in an attempt to pacify the situation. At this juncture, the appellant struck her on the head with the iron rod. The injury proved fatal. Other accused were alleged to have caused injuries with sticks; however, these allegations were found to be inconsistent and uncorroborated.

Medical evidence, including the wound certificate and post-mortem report, established a direct nexus between the appellant’s act and the death. The Trial Court found the testimony against the appellant to be consistent with the complaint and police statements, whereas the accusations against the co-accused appeared exaggerated and absent from the earliest version of events.

The High Court accepted that the appellant himself had sustained injuries and had attempted to lodge a complaint, indicating a mutual fight rather than a pre-planned attack. These circumstances led to reclassification of the offence under Section 304 Part II IPC.

E) LEGAL ISSUES RAISED

i. Whether conviction can be sustained primarily on the testimony of related or interested witnesses?
ii. Whether acquittal of co-accused mandates extension of benefit of doubt to the appellant on the principle of parity?
iii. Whether the maxim falsus in uno falsus in omnibus requires rejection of the entire prosecution evidence?
iv. Whether the facts attract Exception 4 to Section 300 IPC?

F) PETITIONER / APPELLANT’S ARGUMENTS

The counsel for the appellant submitted that reliance on testimonies of close relatives of the deceased vitiated the conviction. It was argued that once the Trial Court disbelieved the witnesses in relation to co-accused, their testimony could not be selectively relied upon against the appellant. The appellant asserted entitlement to parity and benefit of doubt, contending that the prosecution version lacked credibility and consistency.

G) RESPONDENT’S ARGUMENTS

The State contended that the evidence against the appellant stood on a distinct footing. The ocular evidence was corroborated by medical records and contemporaneous documents. It was argued that Indian law does not mandate rejection of related witnesses per se, nor does acquittal of co-accused dilute proven culpability of the principal offender.

H) RELATED LEGAL PROVISIONS

i. Section 300 IPC – Murder
ii. Exception 4 to Section 300 IPC
iii. Section 304 Part II IPC – Culpable homicide not amounting to murder
iv. Section 324 IPC – Voluntarily causing hurt by dangerous weapons

I) JUDGMENT 

The Supreme Court upheld the High Court’s modification of conviction. It reaffirmed that testimony of related witnesses is admissible, subject to cautious scrutiny, relying upon Sudhakar v. State as cited in the judgment . The Court rejected the argument of automatic parity, reiterating that evidence must be assessed individually, drawing support from Yanob Sheikh v. State of West Bengal as relied upon in the judgment.

The Court further clarified that the maxim falsus in uno falsus in omnibus is not a rule of law in India but a rule of caution, reaffirming principles laid down in Nisar Ali v. State of Uttar Pradesh and reiterated in Rohtas v. State of Haryana.

On facts, the Court agreed that the incident constituted a sudden fight without premeditation. The appellant did not act with cruelty or take undue advantage, satisfying the conditions of Exception 4 to Section 300 IPC. Consequently, conviction under Section 304 Part II IPC was justified. The appeal was dismissed, and the appellant was directed to surrender.

a) RATIO DECIDENDI

The acquittal of co-accused does not entitle the main accused to automatic acquittal when evidence against him is cogent, consistent, and corroborated by medical proof. Testimony of related witnesses is not inherently unreliable and can form the basis of conviction upon careful judicial scrutiny. Exception 4 to Section 300 IPC applies when death is caused during a sudden fight without premeditation or cruelty.

b) OBITER DICTA

The maxim falsus in uno falsus in omnibus has limited application in Indian criminal trials and should not be mechanically invoked to discard otherwise credible evidence.

c) GUIDELINES

i. Courts must assess evidence against each accused independently.
ii. Related witness testimony requires caution, not rejection.
iii. Exception 4 to Section 300 IPC must be applied contextually, not mechanically.

J) CONCLUSION & COMMENTS

The judgment reinforces pragmatic criminal adjudication. It balances doctrinal purity with factual nuance. The Court’s reasoning strengthens evidentiary evaluation standards and prevents miscarriage of justice through rigid application of maxims. The decision stands as a reaffirmation of judicial restraint and analytical clarity.

K) REFERENCES

a) Important Cases Referred

i. Sudhakar v. State, [2018] 4 SCR 612
ii. Yanob Sheikh v. State of West Bengal, [2012] 13 SCR 1150
iii. Nisar Ali v. State of Uttar Pradesh, [1957] SCR 657
iv. Rohtas v. State of Haryana, (2019) 10 SCC 554

b) Important Statutes Referred

i. Indian Penal Code, 1860