A) ABSTRACT / HEADNOTE

Yuvraj Laxmilal Kanther & Anr. v. State of Maharashtra examines whether the trial court and the High Court were justified in refusing to discharge two accused persons under Section 227 CrPC where two employees died after being electrocuted and falling from an iron ladder while working on a shop signboard. Appellant No.1 was a contractor engaged in interior decoration and Appellant No.2 was the store operations manager of the lessee company.

The investigating agency charged the appellants under Sections 304A/182/201 read with Section 34 IPC, but the Magistrate committed the case for trial under Section 304 Part II IPC; the Sessions Court and High Court treated the material as sufficient to proceed and dismissed discharge applications. The Supreme Court analysed the mens rea requirement of Section 304 Part II IPC namely the presence of knowledge that the act was likely to cause death but absence of intention to cause death and held that the record did not disclose either intention or the requisite knowledge.

The Court emphasised that at the discharge stage (under Section 227 CrPC) the test is whether there are sufficient materials to justify a trial, not a threadbare or conclusive evaluation of prosecution evidence. Applying that test, the Court found no prima facie case under Section 304 Part II or even Section 304A on the facts, distinguishing Keshub Mahindra v. State of M.P. on its peculiar and catastrophic facts. The orders of the Trial Court and High Court were set aside and the appellants discharged.

Keywords: Discharge, Section 304 Part II IPC, Section 227 CrPC, knowledge, intention, electrocution, safety equipment, prima facie, Keshub Mahindra.

B) CASE DETAILS

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The appeal arises from an incident dated 27.09.2013 where two employees engaged by the contractor (Appellant No.1) were working on a signboard about 12 feet above ground and were electrocuted and fell from an iron ladder; both died on arrival at hospital. An accidental report under Section 174 CrPC was recorded and on 04.12.2013 an FIR was registered alleging lack of provision of safety gear (belt, helmet, rubber shoes) and charging the appellants with offenses under Sections 304A/182/201 IPC read with Section 34.

The chargesheet named both appellants; the Magistrate, however, perceived material to invoke Section 304 Part II IPC and committed the matter to the Sessions Court. The appellants moved to discharge under Section 227 CrPC asserting absence of prima facie material of intention or knowledge and pointing to the accidental character of the event and remedial acts such as compensation and employment provision to a family member. The Sessions Court and subsequently the High Court refused discharge, applying the prudent person standard and treating the non-provision of safety measures as giving rise to strong suspicion of culpability.

The appellants challenged the High Court order before this Court by special leave, contending that neither knowledge nor intention within Section 304 Part II was made out and that the threshold for discharge had not been crossed. The Supreme Court examined the statutory ingredients of Section 304 Part II, distinguished catastrophic precedents, and restated the limited scope of inquiry at the discharge stage, ultimately allowing discharge.

D) FACTS OF THE CASE

The operative facts are succinct. Appellant No.1 was a contractor engaged in interior decoration of a leased shop and Appellant No.2 was the store operations manager of the lessee company. On 27.09.2013 two employees of the contractor, Salauddin Shaikh and Arun Sharma, were provided an iron ladder to work on the shop’s signboard roughly 12 feet high. While working they were struck by electricity, electrocuted, fell from the ladder, sustained head and limb injuries and were declared dead on arrival at Pune Hospital and Research Centre.

Initial accidental reports (Nos. 67/23 and 68/23) under Section 174 CrPC were recorded and, after a gap, FIR No.316/2013 was registered alleging lack of provision of safety equipment and criminal culpability for the unnatural deaths. The police chargesheet accused the appellants under Sections 304A/182/201 read with Section 34 IPC, but the Magistrate pointed to material attracting Section 304 Part II and committed to Sessions.

The appellants were arrested and released the same day, sought discharge under Section 227 CrPC asserting absence of overt acts, lack of negligence reaching criminality, and absence of knowledge/intent. The Sessions Court denied discharge; the High Court dismissed revision, finding strong suspicion. The appellants appealed to this Court.

E) LEGAL ISSUES RAISED

i. Whether the materials on record disclose prima facie ingredients of culpable homicide not amounting to murder under Section 304 Part II IPC against the appellants?
ii. Whether absence of provision of safety gear and the use of an iron ladder, standing alone, suffice to found criminal culpability under Sections 304A or 304 Part II IPC at the discharge stage?
iii. What is the correct legal test and scope of judicial inquiry at the discharge stage under Section 227 CrPC?

F) PETITIONER / APPELLANT’S ARGUMENTS

The counsels for Petitioners submitted that the deaths were accidental without any overt or positive act by the appellants that could constitute culpable homicide; the prosecution’s narrative rests only on non-provision of safety gear which does not translate into knowledge that death was likely. It was contended that the committing Magistrate overreached by substituting an inference of knowledge, the Sessions Court and High Court erred in conducting a detailed appraisal beyond the narrow threshold at discharge, and that even accepting prosecution statements, conviction was improbable. The appellants also pointed to compensatory payments and welfare measures (specific sums paid and employment provided) as evidence of remedial conduct and absence of culpability.

G) RESPONDENT’S ARGUMENTS

The counsels for Respondent submitted that appellants were aware of the risks attendant to the job and yet failed to provide basic safety apparatus; such omissions manifested a culpable consciousness and amounted at least to rash or negligent conduct under Section 304A and, given the gravity, prima facie material existed under Section 304 Part II read with Section 34. Reliance was placed on statutory duties and on Keshub Mahindra v. State of M.P. to show instances where omission and operational faults gave rise to framed charges. The respondent argued the existence of strong suspicion and that trial should proceed.

H) JUDGMENT

The Court commenced with a textual and purposive reading of Section 304 Part II IPC, isolating the tripartite ingredients: commission of culpable homicide as defined in Section 299 IPC, presence of knowledge that the act is likely to cause death and absence of intention to cause death. The judgment underscored that culpable homicide requires a positive act done with either intention or knowledge; without knowledge the Section cannot be attracted. Applying that standard to the record, the Court observed nothing to show that appellants had the requisite knowledge that asking employees to work on an iron ladder would likely cause death by electrocution and fall.

The Court reiterated that the scope of inquiry at Section 227 CrPC stage is limited the court need only determine if there are sufficient grounds to proceed to trial but must not conduct a detailed appraisal of evidence. On the facts, the Court found the incident to be purely accidental and that the ingredients of Section 304 Part II and even Section 304A were not prima facie established. The Court also considered the prosecution’s reliance on Keshub Mahindra, but distinguished it on its catastrophic facts and held it inapplicable for broader reasons. In consequence, both the Sessions Court and High Court had erred in refusing discharge. The orders below were set aside; discharge granted.

a. RATIO DECIDENDI

The controlling ratio is that Section 304 Part II IPC requires knowledge that the act is likely to cause death. Mere omission to provide safety gear or an infirmity in workplace arrangements does not, without more, manifest the requisite knowledge. At the discharge stage under Section 227 CrPC, courts must only test whether the prosecution has produced material which, if accepted, would justify a trial; they must not embark on an exhaustive analysis. Where the record does not disclose either intention or knowledge, a charge under Section 304 Part II cannot be sustained even prima facie.

b. OBITER DICTA

The Court observed that compensation or remedial steps taken by accused are not determinative but may be relevant to context and conduct. The judgment also noted that prudent person assessments by appellate courts should not morph into standards of criminal liability without connecting mental culpability to the act. Finally, while acknowledging catastrophic precedents where omission and operational recklessness attracted criminality, the Court cautioned against loose transposition of such reasoning into comparatively discrete workplace accidents.

c. GUIDELINES 

i. At discharge under Section 227 CrPC, the court must confine itself to whether materials on record make out prima facie case; avoid threadbare evaluations.
ii. For Section 304 Part II IPC, prosecution must produce material to show that the accused had knowledge that the act was likely to cause death; omissions alone are insufficient without such mental element.
iii. Distinguish between regulatory/compensatory failures and criminal mental culpability; workplace safety lapses may ground civil/regulatory consequences without rising to culpable homicide absent knowledge.

I) CONCLUSION & COMMENTS

The Supreme Court’s decision reinforces the protective threshold that the criminal law must cross before persons are made to stand trial for culpable homicide. By focusing on the knowledge requirement of Section 304 Part II and reasserting the limited function of the discharge stage, the judgment prevents premature criminalization of accidents lacking mens rea. The ruling preserves the distinction between civil/regulatory accountability for safety lapses and criminal liability that requires a culpable mental state. Practically, investigators and prosecutors must build positive material to show knowledge or deliberate disregard to justify grave charges; courts must guard against elevating negligence simpliciter into culpable homicide without evidentiary foundation. The decision strikes a balance between the need to prosecute genuine criminal culpability in cases of unsafe operations and the imperative to protect individuals from unfounded criminal trials when the incident is genuinely accidental.

J) REFERENCES

a. Important Cases Referred
i. Yuvraj Laxmilal Kanther & Anr. v. State of Maharashtra, Criminal Appeal No.2356 of 2024, Judgment dated 07 March 2025, [2025] 3 S.C.R. 502 : 2025 INSC 338.
ii. Keshub Mahindra v. State of M.P., (1996) 6 SCC 129; [1996] Supp. 6 SCR 285.

b. Important Statutes Referred
i. Indian Penal Code, 1860 — Sections 299, 300, 304 Part II, 304A, 34.
ii. Code of Criminal Procedure, 1973 — Sections 174, 227.
iii. Constitution of India (referred for Article 142 exercise in precedent discussions).