Maniklal Sahu v. State of Chhattisgarh 2025 INSC 1107 - S.307 IPC - Attempt To Murder
Apex Court Clarifies Section 307 IPC: Intention, Not Just Injury, Key; Delayed Death from Natural Complications Still Murder
Indian Penal Code 1860 - Section 300, 302,307 - Broad principles - a. If it is proved that the injury was fatal and the intention was to cause death, though the death occurred after several days of septicaemia or other complications having supervened, yet it is undoubtedly a murder as it falls within the first limb of Section 300 of the IPC. b. If it is proved that the injuries by themselves were sufficient to cause death in the ordinary course of nature, and if it is established that those injuries were the intended injuries, though the death might have occurred after septicaemia or other complications had supervened, yet the act of the accused would squarely fall under the third limb of Section 300 of the IPC and the accused is therefore liable to be punished under Section 302 of the IPC. c. If it is proved that the injuries were imminently dangerous to life, though the death had occurred after septicaemia or other complications had supervened, yet the act of the accused would squarely fall under the fourth limb of Section 300 of the IPC, provided, the other requirements like knowledge on the part of the accused, etc. are satisfied and so the accused would be liable to be punished under Section 302 of the IPC. Here also, the primary cause of the death is the injuries and septicaemia. d. In judging whether the injuries inflicted were sufficient in the ordinary course of nature to cause death, the possibility that skilful and efficient medical treatment might prevent the fatal result is wholly irrelevant. e. If the supervening causes are attributable to the injuries caused, then the person inflicting the injuries is liable for causing death, even if death was not the direct result of the injuries. f. Broadly speaking, the courts would have to undertake the exercise to distinguish between two types of cases; first, where the intervening cause of death, like peritonitis, is only a remote and a rather improbable consequence of the injury; then it can be said that the injury is one which may, in particular circumstances, result in death, but which may not in ordinary course of nature be likely to lead to it. Secondly, where the complication which is the intervening cause of death is itself a practically inevitable sequence to the injury. In that event, the probability is very high indeed, amounting to practical certainty i.e., death is a result in due course of natural events. A deep abdominal thrust with a knife followed by injury to the internal organs is practically certain to result in acute peritonitis causing death. It is clearly a case of murder under Section 302 and not merely of culpable homicide. g. Even when the medical evidence does not say that any one of the injuries on the body of the deceased was sufficient to cause death in the ordinary course of nature, yet it is open to the Court to look into the nature of the injuries found on the body of the deceased and infer from them that the assailants intended to cause death of the deceased. If none of the injuries alone were sufficient in the ordinary course of nature to cause the death of the deceased, cumulatively, they may be sufficient in the ordinary course of nature to cause his death. h. What the courts must see is whether the injuries were sufficient in the ordinary course of nature to cause death, or to cause such bodily injuries as the accused knew to be likely to cause death although death was ultimately due to supervention of some other cause. An intervening cause or complication is by itself not of such significance. What is significant is whether death was only a remote possibility, or is one which would have occurred in due course. i. To sum it up, where death is delayed due to later complications or developments, the courts should consider the nature of the injury, complications or the attending circumstances. If the complications or developments are the natural, or probable, or necessary consequence of the injury, and if it is reasonably contemplated as its result, the injury could be said to have caused death. If on the other hand, the chain of consequences is broken, or if there is unexpected complication causing new mischief, the relation of cause and effect is not established, or the causal connection is too remote then the injury cannot be said to have caused death. If the original injury itself is of a fatal nature, it makes no difference that death is actually caused by a complication naturally flowing from the injury and not the injury itself, since causal connection is proximate
Indian Penal Code 1860 - Section 307 - A person commits an offence under Section 307 of the IPC when he has the intention to commit murder and in pursuance of that intention, does an act towards its commission irrespective of the fact whether that act is the penultimate act or not. The provision requires that the act must be done with such intention, or knowledge, or in such circumstances that if death be caused by that act, the offence of murder will emerge- Causing an injury that would endanger life is not an essential condition for the applicability of Section 307 of the IPC. Even if the injuries inflicted are simple in nature, that by itself cannot be a ground for acquittal, if the offence otherwise falls under Section 307 IPC. (Para 31) The relevant circumstances from which the intention can be gathered - A suggestive, and not exhaustive list:- 1. the nature of the weapon used; 2. the manner in which the weapon was used; 3. the part of the body where the injuries were inflicted; 4. the nature of the injuries caused; 5. the opportunity available which the accused gets. (Par 32)
What was the central legal question addressed in the case of Maniklal Sahu v. State of Chhattisgarh?
The central legal question in Maniklal Sahu v. State of Chhattisgarh was whether the High Court erred in altering the conviction of the appellant from murder (Section 302 IPC) to attempt to commit murder (Section 307 IPC) based on the delayed death of the victim. Specifically, the Supreme Court examined the application of the theory of causation when death ensues after a significant delay, and whether intervening medical complications (like septicemia and pneumonia) break the chain of causation linking the initial injuries to the ultimate death.
What were the factual circumstances leading to the charges against Maniklal Sahu?
On February 22, 2022, Maniklal Sahu and three co-accused trespassed into Rekhchand Verma's house, dragged him to the terrace, and threw him down. They then assaulted him with sticks and fisticuffs. Rekhchand was critically injured and remained hospitalized for about nine months, during which he gave both written and oral dying declarations naming his assailants. He ultimately died on November 8, 2022, due to septicemia and pneumonia, leading to cardiorespiratory arrest. Initially charged with lesser offenses, Section 302 of the IPC (murder) was added after his death.
What was the High Court's reasoning for changing the conviction from murder to attempted murder?
The High Court acknowledged the grievous nature of the injuries and that Rekhchand's death was due to complications arising from his spinal cord injury, which led to him becoming bedridden and developing infections. However, the High Court concluded that because Rekhchand died approximately nine months after the incident due to "lack of proper treatment," the case fell under Section 307 IPC (attempt to commit murder) rather than Section 302 IPC (murder). They also noted that the trial court had already convicted the appellants under Section 307/34 IPC for the same offense, implying no need for a murder conviction.
Differentiate between Section 307 (Attempt to Murder) and Section 302 (Murder) of the IPC, especially concerning intention and knowledge?
The Supreme Court emphasizes that the most important ingredient for an offense under Section 307 IPC is the "intention or knowledge" to cause death, as outlined in Section 300 IPC. This intention can be inferred from circumstantial evidence such as the nature of the weapon, the manner of its use, the part of the body injured, the nature of the injuries, and the opportunity the accused had. It's crucial that the act itself has the potential to cause death, even if the injuries inflicted are simple or if death does not ensue. For murder (Section 302), the act must cause death with the intention of causing death, or causing bodily injury known to be likely to cause death, or causing bodily injury sufficient in the ordinary course of nature to cause death, or performing an imminently dangerous act likely to cause death. The key distinction for attempt to murder is the "potential" of the act and the "intention" behind it, irrespective of the immediate outcome.
What is the "Theory of Causation" and how is it applied in cases where death occurs after a delay, according to the Supreme Court?
The "Theory of Causation" determines whether an initial act of violence is legally responsible for a subsequent death, even if there are intervening factors. The Supreme Court clarifies that medical phrases like "disease" (e.g., septicemia, pneumonia) should not obscure the causal link if the original injury set in motion a chain of events leading to these conditions. If the complications are natural, probable, or necessary consequences of the initial injury, and reasonably contemplated as its result, the injury is considered to have caused death. The absence of "proper treatment" or the possibility of prevention by skillful treatment does not break this chain of causation, as per Explanation 2 to Section 299 IPC. The Court rejects the notion that a long interval between injury and death automatically diminishes liability from murder to culpable homicide.
What was the medical evidence presented in the case and how did it support the Supreme Court's conclusion?
The medical evidence from Dr. Sheetal Kaushal (PW-9), Dr. Twinkle Chandrakar (PW-24), and Dr. Abhishek Shrivastava (PW-28) consistently indicated that Rekhchand Verma died due to cardiorespiratory arrest caused by septic shock with bilateral pneumonia, post-traumatic spinal cord injury with paraplegia, and infected bedsores leading to hepatic dysfunction. These conditions were directly attributed to the initial injuries sustained during the assault. Dr. Chandrakar explicitly stated that the death was "due to spinal cord injury." Dr. Shrivastava confirmed that septic shock was caused by infection of the body's injuries. The doctors' testimonies made it clear that the complications were a direct result of the initial grievous injuries, and there was no evidence suggesting "lack of proper treatment."
What broad principles did the Supreme Court outline for courts to consider in similar cases involving delayed death and intervening complications?
The Supreme Court outlined several key principles:
- If a fatal injury intended to cause death leads to death after complications, it's murder (Section 300, first limb).
- If injuries are sufficient in the ordinary course of nature to cause death, and were intended, it's murder (Section 300, third limb), even with supervening complications.
- If injuries are imminently dangerous to life and cause death after complications, it's murder (Section 300, fourth limb), provided the accused had the necessary knowledge.
- The possibility of preventing death through skillful medical treatment is irrelevant when judging if injuries were sufficient to cause death.
- If supervening causes are attributable to the initial injuries, the person inflicting them is liable for death.
- Courts must distinguish between remote and improbable intervening causes and those that are practically inevitable consequences of the injury.
- Courts can infer intent to cause death from the nature and cumulative effect of injuries, even if no single injury was individually fatal.
- The critical factor is whether death was a remote possibility or a probable consequence of the injuries, regardless of intervening complications.
- When death is delayed, the focus is on whether complications are a natural, probable, or necessary consequence of the injury, establishing a proximate causal connection.
Case Info
The case is Maniklal Sahu v. State of Chhattisgarh, decided on 12 September 2025 by the Supreme Court of India (2025 INSC 1107).
Case Name and Neutral Citation
- Case Name: Maniklal Sahu v. State of Chhattisgarh
- Neutral Citation: 2025 INSC 1107
Coram
- Judges: J.B. Pardiwala, R. Mahadevan
Judgment Date
- Date: 12th September, 2025
Caselaws and Citations Referred
The judgment refers to several important cases and legal authorities:
- Sreedharan v. State of Kerala, 1969 SCC OnLine Ker 46
- Reg. v. Cassidy, (1867) 4 Bom. H.C. (Cr. C.) 17
- Emperor v. Vasudeo Balwant Gogte, 1932 SCC OnLine Bom 1
- R. v. Whybrow, (1951-35-Crl. Appl. 141)
- Director of Public Prosecutions v. Smith, (1961-AC. 290)
- R v. Grimwood, (1962-(3)-AER. 285)
- Brintons Ltd. v. Turvey, 1905 AC 230
- R. v. Holland, (1841) 2 M and Rob 351; (1904) 1 Cri LJ 909
- Nga Moe v. The King, AIR 1941 Rang 141
- In re, Doraswami, 1943 SCC OnLine Mad 208
- Prasad Pradhan & Anr. v. State of Chhattisgarh, (2023) 11 SCC 320
- Sudershan Kumar v. State of Delhi, (1975) 3 SCC 831
- Patel Hiralal Joitaram v. State of Gujarat, (2002) 1 SCC 22
- Om Parkash v. State of Punjab, (1992) 4 SCC 212
- State of Haryana v. Pala & Ors., (1996) 8 SCC 51
- Jagtar Singh & Anr. v. State of Punjab, (1999) 2 SCC 174
Statutes/Laws Referred
The judgment discusses and interprets several sections of the Indian Penal Code (IPC):
- Section 299: Culpable homicide
- Section 300: Murder
- Section 302: Punishment for murder
- Section 307: Attempt to murder
- Section 304: Punishment for culpable homicide not amounting to murder
- Section 323, 294, 506(B), 458: Other IPC sections mentioned in the factual matrix
The judgment also refers to legal principles from:
- Mayne’s Criminal Law of India
- Russel on Crime
- Taylor’s Principles and Practice of Medical Jurisprudence
- Modi’s Medical Jurisprudence and Toxicology
- The Essentials of Modern Surgery by Handfield Jones and Pokitt
In this judgment, #SupremeCourt clarifies that, for Section 307 IPC: Intention, Not Just Injury, Key; Delayed Death from Natural Complications Still Murder https://t.co/CVi0bLqPEi pic.twitter.com/yNoitOexau
— CiteCase 🇮🇳 (@CiteCase) September 13, 2025
