Nandkumar @ Nandu Manilal Mudaliar v. State of Gujarat 2025 INSC 1302 - Murder - Culpable Homicide
Indian Penal Code 1860 - Section 299-304 - Allowing appeal against conviction in a murder case, SC observed: Looking to the kind and nature of injuries which is available from the medical evidence, it could not be said that the injuries were not of the nature which were sufficient to cause death in ordinary course. The assailant used knife and inflicted serious injuries on the body of the deceased, including below the belly. Looking to the act on part of the appellant, it has to be concluded that the accused was liable to be attributed with the knowledge that the injuries which he was to inflict by using the weapon in hand, would be sufficient to result into death in ordinary course. (Para 6) Coinviction of the appellant deserves to be converted from under Section 302, IPC to under Section 304 Part I, IPC. The act on part of the appellant has to be treated as ‘culpable homicide not amounting to murder’ falling under Section 304 Part I, IPC. (Para 7)
Case Info
Case Details
- Case name: Nandkumar @ Nandu Manilal Mudaliar v. State of Gujarat.
- Neutral citation: 2025 INSC 1302.
- Coram: Justice K. Vinod Chandran and Justice N.V. Anjaria.
- Judgment date: November 10, 2025.
- Appeal number: Criminal Appeal No. 1266 of 2014.
- Court: Supreme Court of India, Criminal Appellate Jurisdiction.
Outcome
- Conviction under Section 302 IPC converted to Section 304 Part I IPC.
- Sentence treated as the 14 years already undergone; bail bond discharged.
- Appeal allowed to that extent.
Statutes / Laws Referred
- Indian Penal Code, 1860: Sections 299 (culpable homicide), 300 (murder and exceptions), 302, 304 Part I, 304 Part II, 324, 504.
- Code of Criminal Procedure, 1973: Section 313.
Case Laws & Citations
- Kesar Singh & Anr. v. State of Haryana, (2008) 15 SCC 753.
- Virsa Singh v. State of Punjab, AIR 1958 SC 465.
- Shankar Narayan Bhadolkar v. State of Maharashtra, citation not specified in text.

