Supreme Court Upholds Conviction Under Section 302 IPC in Land Dispute Homicide Case. Premeditation and Use of Deadly Weapons Establish Murder – Appeal Dismissed


Summary of Judgement

Premeditation and Intent: Armed trespass and targeting a vital body part (head) with deadly weapons conclusively proved murder under Section 302 IPC (Para 13). Credibility of Related Witnesses: Injured eyewitnesses’ testimony cannot be discarded solely due to familial ties (Para 5–6). Medical Evidence: A doctor’s opinion on alternative causes of injury (e.g., accidental fall) is irrelevant when overt acts are corroborated by eyewitnesses (Para 12).

The Supreme Court dismissed the appeal, upholding the conviction under Section 302 read with Section 34 IPC.
Held: The accused’s armed intrusion and attack on a vital body part (head) established intent to kill (Para 13). Eyewitness testimony (PW1–PW3) was credible despite their relationship to the deceased, as they were injured in the same transaction (Para 6). Medical evidence did not negate the ocular testimony of a deliberate blow (Para 12).

Major Acts and Sections:
Indian Penal Code, 1860 (IPC): Section 302: Punishment for murder. Section 304 Part II: Culpable homicide not amounting to murder. Section 323: Punishment for voluntarily causing hurt. Section 324: Voluntarily causing hurt by dangerous weapons or means. Section 34: Acts done by several persons in furtherance of common intention. Section 341: Punishment for wrongful restraint. Section 506: Punishment for criminal intimidation.

Facts:
The appellants, Maukam Singh and others, were convicted under Section 302 read with Section 34 IPC for the murder of the deceased, who died from head injuries sustained during a scuffle. The incident arose from a land dispute involving the worship of a deity installed on disputed property.
The accused, armed with deadly weapons (axe and cutting tools), trespassed into the deceased’s house, leading to a violent altercation. The deceased’s grandchildren (PW1–PW3) were injured eyewitnesses.
The Trial Court and High Court convicted the appellants under Section 302 IPC, sentencing them to life imprisonment. The appellants argued for a lesser charge under Section 304 Part II IPC, citing lack of premeditation and accidental injury.

Issues:

  1. Whether the appellants’ actions fell under Section 302 IPC (murder) or Section 304 Part II IPC (culpable homicide not amounting to murder)?

  2. Whether the eyewitness testimony of the injured grandchildren (PW1–PW3) was credible despite their relationship to the deceased?

  3. Whether the fatal injury could have been caused by an accidental fall, as suggested by the medical evidence?

Submissions/Arguments:
Appellants:

  • Argued no premeditation or intention to kill; injury could have resulted from an accidental fall during the scuffle (Para 3).

  • Cited medical evidence (PW11) stating the fatal injury could be caused by a blunt object or fall (Para 11).Respondent-State:

  • Asserted premeditation, armed trespass, and intent to kill, corroborated by eyewitnesses and medical reports (Para 4).

  • Highlighted the severity of the head injury inflicted with the reverse side of an axe (Para 13).

Subjects:
Murder, Section 302 IPC, common intention, deadly weapons, premeditation, ocular testimony, land dispute, fatal injury.

Case Title: MAUKAM SINGH & OTHERS VERSUS STATE OF MADHYA PRADESH

Citation: 2025 LawText (SC) (4) 13

Case Number: CRIMINAL APPEAL NO…………..OF 2025 [@ SPECIAL LEAVE PETITION (CRL) NO.13369 OF 2024]

Date of Decision: 2025-04-02