Four Stabs, One Unarmed Man: Inside the Supreme Court’s Brutal Ruling on Rage vs. Murder

 

We’ve all seen it or felt it: a heated argument spirals out of control. Voices rise, tempers flare, and in a flash, something irreversible happens. It's a human tragedy, but it's also a profound legal question: Where does society, and the law, draw the line between a tragic loss of control and cold-blooded murder?

The Indian Supreme Court recently clarified this very line in a landmark case, Surender Kumar v. State of Himachal Pradesh (2025). The judgment delves deep into a specific legal provision known as "Exception 4" of the Indian Penal Code, which can reduce a murder charge to the lesser offense of culpable homicide if the death occurred during a "sudden fight."

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Closing the Loophole: The Virsa Singh Doctrine and the End of Intent-Based Defenses

The Virsa Singh v. State of Punjab (1958) case is a foundational judgment of the Supreme Court of India that fundamentally shaped the interpretation of murder under Section 300 of the Indian Penal Code. This landmark ruling established crucial principles regarding criminal liability that continue to guide Indian criminal jurisprudence today.

Background and Facts

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When a Push Becomes Fatal: Understanding Murder vs Culpable Homicide Under Indian Law

 A legal analysis of unintended deaths resulting from physical altercations

Introduction

In everyday disputes, a simple push might seem like a minor act of aggression. However, when such an act results in death—as in cases where someone falls and hits their head on a stone—the legal consequences can be severe. The critical question that arises is: does this constitute murder or a lesser charge under Indian criminal law? This article examines the legal framework governing such scenarios and explains how courts differentiate between murder and culpable homicide.

The Legal Distinction: Murder vs Culpable Homicide

Understanding Culpable Homicide (Section 299 IPC)

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Supreme Court: Under which circumstances accused can be convicted for murder even if prosecution fails to prove his intention to commit murder?

Now, the question is whether in the present case, the offence of culpable homicide not amounting to murder is made out. Obviously in this case, none of the exceptions to Section 300 are applicable. The issue which is required to be examined is whether the case will be covered by "thirdly" in Section 300. On this aspect, we will make a reference to a decision of this Court in the case of Virsa Singh v. The State of Punjab   MANU/SC/0041/1958 : AIR 1958 SC 465 : 1958 SCR 1495 which has stood the test of time.

Paragraphs 12 and 13 of the said decision which are locus classicus read thus:

12. To put it shortly, the prosecution must prove the following facts before it can bring a case Under Section 300, "Thirdly";

First, it must establish, quite objectively, that a bodily injury is present;

Secondly, the nature of the injury must be proved; These are purely objective investigations.

Thirdly, it must be proved that there was an intention to inflict that particular bodily injury, that is to say, that it was not accidental or unintentional, or that some other kind of injury was intended.

Once these three elements are proved to be present, the enquiry proceeds further and,

Fourthly, it must be proved that the injury of the type just described made up of the three elements set out above is sufficient to cause death in the ordinary course of nature. This part of the enquiry is purely objective and inferential and has nothing to do with the intention of the offender.

13. Once these four elements are established by the prosecution (and, of course, the burden is on the prosecution throughout) the offence is murder Under Section 300, "Thirdly. It does not matter that there was no intention to cause death. It does not matter that there was no intention even to cause an injury of a kind that is sufficient to cause death in the ordinary course of nature (not that there is any real distinction between the two). It does not even matter that there is no knowledge that an act of that kind will be likely to cause death. Once the intention to cause the bodily injury actually found to be present is proved, the rest of the enquiry is purely objective and the only question is whether, as a matter of purely objective inference, the injury is sufficient in the ordinary course of nature to cause death. No one has a licence to run around inflicting injuries that are sufficient to cause death in the ordinary course of nature and claim that they are not guilty of murder. If they inflict injuries of that kind, they must face the consequences; and they can only escape if it can be shown, or reasonably deduced that the injury was accidental or otherwise unintentional."

 IN THE SUPREME COURT OF INDIA

Criminal Appeal No. 1519 of 2021 

Decided On: 30.11.2021

Vinod Kumar Vs. Amritpal and Ors.

Hon'ble Judges/Coram:

Ajay Rastogi and Abhay Shreeniwas Oka, JJ.

Author: Abhay Shreeniwas Oka, J.

Citation:  MANU/SC/1167/2021

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Understanding the Difference Between Murder and Culpable Homicide in Indian Law with examples

 Difference Between Murder and Culpable Homicide

Legal Definitions and Key Distinction

• Culpable Homicide (Section 299, IPC): Refers to causing death by doing an act with the intention of causing death, or with the intention of causing such bodily injury as is likely to cause death, or with the knowledge that such act is likely to cause death. The intent here may not always be direct or absolute.

• Murder (Section 300, IPC): Is a specific form of culpable homicide where the act is done with a clear, deliberate intention to cause death or such bodily injury as is sufficient in the ordinary course of nature to cause death, or with knowledge that the act is so imminently dangerous that it must, in all probability, cause death.

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Leading Supreme Court on essentials to be proved for getting benefit of S 300 IPC exception 4,sudden fight

6. Exception 4 to Section 300 reads as under:

Exception 4 : Culpable homicide is not murder if it is committed without premeditation in a sudden fight in the heat of passion upon a sudden quarrel and without the offender having taken under advantage or acted in a cruel or unusual manner:

Explanation: It is immaterial in such cases which party offers the provocation or commits the first assault.

7. To invoke this exception four requirements must be satisfied, namely, (i) it was a sudden fight ; (ii) there was no premeditation ; (iii) the act was done in a heat of passion ; and (iv) the assailant had not taken any undue advantage or acted in a cruel manner. The cause of the quarrel is not relevant nor is it relevant who offered the provocation or started the assault. The number of wounds caused during the occurrence is not a decisive factor but what is important is that the occurrence must have been sudden and unpremeditated and the offender must have acted in a fit of anger. Of course, the offender must not have taken any undue advantage or acted in a cruel manner. Where, on a sudden quarrel, a person in the heat of the moment picks up a weapon which is handy and causes injuries, one of which proves fatal, he would be entitled to the benefit of this exception provided he has not acted cruelly.

 IN THE SUPREME COURT OF INDIA

Criminal Appeal No. 530 of 1978

Decided On: 08.03.1989

Surinder Kumar Vs. Union Territory, Chandigarh

Hon'ble Judges/Coram:

A.M. Ahmadi and S. Natarajan, JJ.

Coram: A.M. Ahmadi, J.

Citation: (1989) 2 SCC 217,AIR 1989 SC 1094,MANU/SC/0589/1989.

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What is importance of intention in determining whether an offence is murder or culpable homicide?

 The decision in State of Andhra Pradesh v Rayavarapu Punnayya & Anr 1976 (4) SCC 382 notes the important distinction between the two provisions, and their differing, but subtle distinction. The court pertinently pointed out that:

"12. In the scheme of the Penal Code, "culpable homicide" is genus and "murder" its specie. All "murder" is "culpable homicide" but not vice- versa.

Speaking generally, "culpable homicide" sans "special characteristics of murder", is "culpable homicide not amounting to murder". For the purpose of fixing punishment, proportionate to the gravity of this generic offence, the Code practically recognises three degrees of culpable homicide. The first is,

what may be called, "culpable homicide of the first degree". This is the greatest form of culpable homicide, which is defined in Section 300 as "murder". The second may be termed as "culpable homicide of the second degree". This is punishable under the first part of Section 304. Then, there is "culpable homicide of the third degree". This is the lowest type of culpable

homicide and the punishment provided for it is, also, the lowest among the punishments provided for the three grades. Culpable homicide of this degree is punishable under the second part of Section 304..

13. The considerations that should weigh with courts, in discerning whether an act is punishable as murder, or culpable homicide, not amounting to murder, were outlined in Pulicherla Nagaraju @ Nagaraja Reddy v State of Andhra Pradesh5. This court observed that:

"29. Therefore, the Court should proceed to decide the pivotal question of intention, with care and caution, as that will decide whether the case falls under Section 302 or 304 Part I or 304 Part II. Many petty or insignificant

matters - plucking of a fruit, straying of cattle, quarrel of children, utterance

of a rude word or even an objectionable glance, may lead to altercations and

group clashes culminating in deaths. Usual motives like revenge, greed,

jealousy or suspicion may be totally absent in such cases. There may be no

intention. There may be no premeditation. In fact, there may not even be

criminality. At the other end of the spectrum, there may be cases of murder

where the accused attempts to avoid the penalty for murder by attempting to

put forth a case that there was no intention to cause death. It is for the courts

to ensure that the cases of murder punishable under Section 302, are not

converted into offences punishable under Section 304 Part I/II, or cases of

culpable homicide not amounting to murder are treated as murder punishable

under Section 302. The intention to cause death can be gathered generally

from a combination of a few or several of the following, among other,

circumstances; (i) nature of the weapon used; (ii) whether the weapon was

carried by the accused or was picked up from the spot; (iii) whether the blow

is aimed at a vital part of the body;(iv) the amount of force employed in

causing injury; (v) whether the act was in the course of sudden quarrel or

sudden fight or free for all fight; (vi) whether the incident occurs by chance or

whether there was any premeditation; (vii) whether there was any prior

enmity or whether the deceased was a stranger;(viii) whether there was any

grave and sudden provocation, and if so, the cause for such provocation; (ix)

whether it was in the heat of passion; (x) whether the person inflicting the

injury has taken undue advantage or has acted in a cruel and unusual

manner; (xi) whether the accused dealt a single blow or several blows. The

above list of circumstances is, of course, not exhaustive and there may be

several other special circumstances with reference to individual cases which

may throw light on the question of intention.”

REPORTABLE

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPEAL NO. 856 of 2021

MOHD. RAFIQ @ KALLU Vs THE STATE OF MADHYA PRADESH

Author: S. RAVINDRA BHAT, J.

Dated: September 15, 2021.

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What is distinction between sudden quarrel and sudden fight for applicability of S 300 Exception 4 of IPC?

 As observed by this Court in the case of Shivshankar (supra), intention is a matter of inference and when death is as a result of intentional firing, intention to cause death is patent unless the case falls under any of the exceptions. It is further observed and held that Exception 4 to Section 300 Indian Penal Code is attracted only when there is a fight or quarrel which requires mutual provocation and blows by both sides in which the offender does not take undue advantage.

8.3. In the case of Bhagwan Munjaji Pawade v. State of Maharashtra MANU/SC/0063/1978 : (1978) 3 SCC 330, in paragraph 6, this Court has observed and held as under:

6. ... It is true that some of the conditions for the applicability of Exception 4 to Section 300 exist here, but not all. The quarrel had broken out suddenly, but there was no sudden fight between the deceased and the Appellant. 'Fight' postulates a bilateral transaction in which blows are exchanged. The deceased was unarmed. He did not cause any injury to the Appellant or his companions. Furthermore, no less than three fatal injuries were inflicted by the Appellant with an axe, which is a formidable weapon on the unarmed victim. Appellant is therefore, not entitled to the benefit of Exception 4, either.

IN THE SUPREME COURT OF INDIA

Criminal Appeal No. 1670 of 2019 

Decided On: 08.11.2019

 Awadhesh Kumar  Vs.  State of U.P. and Ors.

Hon'ble Judges/Coram:

Arun Mishra, M.R. Shah and S. Ravindra Bhat, JJ.

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Whether Accused Party Armed With Weapons Can Claim Benefit Of Sudden Fight [Exception 4 To S 300 IPC]

It was next urged that the offence was not of murder but

may amount to culpable homicide not amounting to murder. It

has been urged that the case would fall within Exception 4 to

Section 300 IPC, which reads as follows:

“Exception 4 – Culpable homicide is not murder if it is

committed without premeditation in a sudden fight in the

heat of passion upon a sudden quarrel and without the

offender having taken undue advantage or acted in a cruel

or unusual manner.”

7. We are of the view that the accused cannot take benefit of

this Exception. It has come in evidence that all the accused

persons came armed. Two were armed with sickles, one with an

iron pipe and the other with wooden staffs. Even if it is assumed

that they may not have come with the intention of killing, the fact

that they were armed, clearly indicates that the occurrence did

not take place in the heat of passion, upon a sudden quarrel. As

pointed out above, both sides were coming to attend a Panchayat

to settle a dispute. Where was the need to carry arms if the

intention was only to settle a dispute? Even otherwise, we feel

that Exception 4 is not applicable because the manner in which

the blow was given right on the middle of the head, brings this

case squarely within clause “Fourthly” of Section 300 IPC.

REPORTABLE

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPEAL NO. 1893 OF 2010

GURU @ GURUBARAN  Vs  STATE REP. BY INSP. OF POLICE 

Deepak Gupta, J.

Dated:September 27, 2019

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Question and answer on law part 4

1) What is difference between Murder and culpable homicide?

Ans:

1. Culpable homicide is wider than the term murder. Culpable homicide is therefore considered as the genus while as murder is regarded as a species. All murders are culpable homicide but all culpable homicides are not regarded as murder.
2. Murder is an aggravated form of culpable homicide.
3. In murder, the offender has a definite knowledge that the act would result in the death while as in culpable homicide the knowledge is not so definite.
4. The probability of causing death is higher in murder than culpable homicide.

Q 2:- Whether easement can be suspended? 

Ans:- Section 49 in The Indian Easements Act, 1882

49. Suspension of easement.-An easement is suspended when the dominant owner becomes entitled to possession of the servient heritage for a limited interest therein, or when the servient owner becomes entitled to possession of the dominant heritage for a limited interest therein.

Q 3:- What is doctrine of colourable legislation?

Ans:-  It may be made clear at the outset that the doctrine of colourable legislation does not involve any question of bona fides or mala fides on the part of the legislature. The whole doctrine resolves itself into the question of competency of a particular legislature to enact a particular law. If the legislature is competent to pass a particular law, the motives which impelled it to act are really irrelevant. On the other hand, if the legislature lacks competency, the question of motive does not arise at all.

Q 4:- What is difference between approver and accomplice?

Ans:- The difference between approver and accomplice is that approver is always an accomplice where as an accomplice is not necessarily an approver as an accomplice or co-accused becomes an approver after he has been tendered a pardon or granted concession on the condition that he will reveal the truth and will not hide anything in relation to offence or offences which he and other accused are alleged to have committed.

Q 5:- Where is provision to record   demeanour of witness in criminal Procedure Code?

Ans:- Section 280 in The Code Of Criminal Procedure, 1973

280. Remarks respecting demeanour of witness. When a presiding Judge or Magistrate has recorded the evidence of a witness, he shall also record such remarks (if any) as he thinks material respecting the demeanour of such witness whilst under examination.

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Whether prosecution for murder can be quashed if suicide note is in handwriting of deceased?

 No doubt, it is recorded
in the post-mortem report that the cause of death in this case was
asphyxia due to ante-mortem hanging and the suicide note is in the
handwriting of deceased, but this by itself cannot rule out the possibility
of murder being committed by petitioners. It is so said because the
suicide note is undated and the aspect of ante-mortem hanging cannot be
considered in abstract by this Court in the light of medical literature,
sought to be relied upon by respondents. Whether death of deceased was

homicidal or suicidal is an aspect which cannot be pre-judged at this initial stage. In any case, presence of lividity over the back and other areas prima facie justifies framing of charge under Section 302/34 IPC, as at this initial stage, only a prima facie opinion is to be formed. 

 IN THE HIGH COURT OF DELHI AT NEW DELHI
Date of Order: March 12, 2019
 CRL.REV.P. 645/2017 & Crl.M.A. 14133/2017

SUKHBIR KATARIA Vs  STATE GOVT OF NCT OF DELHI 

CORAM:
HON'BLE MR. JUSTICE SUNIL GAUR

Citation: 2019 SCC ONLINE Del 7603

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How to appreciate evidence in case of offence of culpable homicide?

 It is well settled that in order to be called a murder, it needs to be culpable homicide in the first place, that is to say all murders are culpable homicides, but the vice versa may not true in all cases. Therefore, we need to ascertain whether a case of culpable homicide is made out herein in the first place. In this context, we need to observe Section 299 of Indian Penal Code at the outset-

299. Culpable homicide.-- Whoever causes death by doing an act with the intention of causing death, or with the intention of causing such bodily injury as is likely to cause death, or with the knowledge that he is likely by such act to cause death, commits the offence of culpable homicide.

(Emphasis supplied)

17. As noted above, causation is an important ingredient to determine as to whether a person commits culpable homicide in the first place. Causation simply means "causal relationship between conduct and result". In this respect we need to assess whether the contentions of the parties could stand the scrutiny of the law of the land. Section 299 of Indian Penal Code indicates two types of causations, one the factual causation and the second the legal causation. Coming to the factual causation, it is a matter of fact as to whether the action of the Accused caused death of the person. But the second aspect concerns itself, whether the death can be sufficiently imputed to the accused's action as being responsible legally. In our considered opinion this case turns on the second leg of causal relationship wherein, could the injuries caused by the police officers be sufficiently imputed to be the cause of death of Joinus herein?

18. It is settled under common law wherein the principle of 'take their victim as they find them' is followed,1 meaning 'A person who does any act/omission which hastens the death of another person who, when the act is done or the omission is made, is labouring under some disorder or disease arising from another cause, is deemed to have killed that other person.' This principle has been expressly ingrained under the Explanation 1 to the Section 299 of Indian Penal Code. Without going into details on this aspect as this is not a case of multiple causation requiring us to consider the same, rather it is a case wherein the deceased died of asphyxiation due to contents of his vomit, hours later from the time when the injury was inflicted, which is an independent reason for cause of death herein.

19. As elucidated above, various other circumstances which disassociate the cause of death to the actions of the Appellant officers are available. It is on record that the injuries noted in the post-mortem report clearly indicate that the nature of these injuries were not grievous. The head injury noted does not show any internal fracture to the skull bone. Therefore, when, on facts, it is concurrently inferred by the courts below that the cause of death was due to asphyxiation, we do not see any reasons for accepting a different factual inference herein, as the same is not perverse.

20. Further, we agree with the reasoning of the High Court on the aspect that the PW-1 (Zarina) has not been completely honest in her statements. She has at times deposed over-zealously, thereby mandating us to be cautious in accepting her evidence. Further no witness has clearly deposed on the aspect of injuries and how they happened to be, except for blank statements that 'beatings were given to the deceased Joinus'. Further we may note that the surrounding circumstances also strengthen our conclusions such as firstly, the condition of the deceased was said to be good as per the statements of PW-21 (cell-inmate) and PW-42 (head constable) although he was suffering from tuberculosis, when he was admitted in the lock-up. Secondly, Joinus (deceased) was heavily inebriated when he was arrested and thirdly, the aspect of asphyxiation which is a significant cause to break the chain of causal link between the death of Joinus and the injuries inflicted by the Appellants herein.

21. As discussed above, the causal link between the injuries caused to the deceased by the erring officers and the death is not connected, therefore, Section 299 of Indian Penal Code is not attracted. Accordingly, there is no question of attracting Section 302 or 304 of Indian Penal Code.

22. In any case this Court in catena of cases has taken a view that, as regards the inference of facts, when two Courts have acquitted the Accused-Appellant of charges Under Section 302 of Indian Penal Code, then it would not be appropriate upon this Court to overturn the factual finding, unless the view taken by the lower courts is shown to be highly unlikely or unreasonable or perverse. Although the learned Counsel for the State has tried to argue that the cumulative effect of the injuries was responsible for the death, but the medical evidence itself, on the other hand affirms the high possibility of death due to asphyxiation. Further there is no material brought before us to portray that the courts below had taken a perverse view. In this light, when two reasonable views are possible, then reversal of concurrent acquittal would not be appropriate herein.

IN THE SUPREME COURT OF INDIA

Criminal Appeal Nos. 385-386, 299, 387-388 of 2008 and 182-187 of 2009

Decided On: 04.09.2018

 Yashwant  Vs.  The State of Maharashtra

Hon'ble Judges/Coram:

N.V. Ramana and Mohan M. Shantanagoudar, JJ.

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SHORT NOTES ON MURDER,CULPABLE HOMICIDE AND SUICIDE

The first offence against human life is culpable homicide. The word 'Homicide' comes from latin word 'homa' means man and 'cide' means cut. Killing of a human being by another human being is homicide.

Kinds if homicide- Homicide is either lawful or unlawful. Lawful homicide includes cases falling under the general exceptions that is S 76 to S 106.

Read important judgments on Murder.
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S 299 of IPC defines culpable homicide as,Whoever causes death,

1. with intention of causing death,
2. with intention of causing such bodily injury as is likely to cause death.
3. With knowledge that he is likely by such act to cause death.
   Explanation to S 299 of IPC.
   

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When culpable homicide will not amount to Murder?

The weapon used in the fight between the parties is ‘Kirpan’ which is used by ‘Amritdhari Sikhs’ as a spiritual tool. In the present case, the Kirpan used by the appellant-accused was a small Kirpan. In order to find out whether the instrument or manner of retaliation was cruel and dangerous in its nature, it is clear from the deposition of the Doctor who conducted autopsy on the body of the deceased that stab wounds were present on the right side of the chest and of the back of abdomen which implies that in the spur of the moment, the appellant-accused inflicted injuries using Kirpan though not on the vital organs of the body of the deceased but he stabbed the deceased which proved fatal. The injury intended by the accused and actually inflicted by him is sufficient in the ordinary course of nature to cause death or not, must be determined in each case on the basis of the facts and circumstances. In the instant case, the injuries caused were the result of blow with a small Kirpan and it cannot be presumed that the accused had intended to cause the inflicted injuries. The number of wounds caused during the occurrence is not a decisive factor but what is important is that the occurrence must have been sudden and unpremeditated and the offender must have acted in a fit of anger. Of course, the offender must not have taken any undue advantage or acted in a cruel manner. It is clear from the materials on record that the incident was in a sudden fight and we are of the opinion that the appellant-accused had not taken any undue advantage or acted in a cruel manner. Where, on a sudden quarrel, a person in the heat of the moment picks up a weapon which is handy and causes injuries, one of which proves fatal, he would be entitled to the benefit of this Exception provided he has not acted cruelly.

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

(Before A.K. Sikri and R.K. Agrawal, JJ.)

Surain Singh .

v.

The State of Punjab .

Criminal Appeal No. 2284 of 2009

Decided on April 10, 2017

Citation: 2017 SCC ONLINE SC364

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Supreme court : Five-step inquiry is necessary for decision in Murder trial

Position in law

 Having considered all the decisions cited before us (and perhaps there are many more on the subject but not cited), in our opinion, a five-step inquiry is necessary: (i) Is there a homicide? (ii) If yes, is it a culpable homicide or a 'not-culpable homicide? (iii) If it is a culpable homicide, is the offence one of culpable homicide amounting to murder (Section 300 of the Indian Penal Code) or is it a culpable homicide not amounting to murder (Section 304 of the Indian Penal Code)? (iv) If it is a 'not-culpable homicide' then a case Under Section 304-A of the Indian Penal Code is made out. (v) If it is not possible to identify the person who has committed the homicide, the provisions of Section 72 of the Indian Penal Code may be invoked. Since this five-pronged exercise has apparently been missed out in the first category of decisions, learned amicus was of the opinion that those decisions require reconsideration.

 In our view none of the decisions require any reconsideration. The position in law is as we have culled out from the cases cited before us making it clear that in most cases the person who has committed homicide (culpable or not culpable) can be identified. But it is quite possible in some cases, such as in Ninaji Raoji Boudha and Ram Lal that conclusive or specific evidence is lacking to actually pin down the person who has committed homicide (culpable or not culpable). In such cases, the accused would have to be given the benefit of Section 72 of the Indian Penal Code. Such cases arise if the investigation is defective or if the evidence is insufficient. But where it is possible to ascertain who is responsible for the homicide, the five-step inquiry can easily be carried out.

Conclusion on facts

 Applying the five-step inquiry, it is clear that: (i) there was a homicide, namely the death of Sunderlal; (ii) the assailants gave two lathi blows to Sunderlal which resulted in the fracture of his ribs and piercing of his lungs. The injuries were not accidental or unintentional-the assailants had a common intention of grievously injuring Sunderlal and it is not as if they intended to cause some injury to him other that the ones inflicted, (iii) the opinion of Dr. Amar Singh Rathore confirmed that the injuries caused to Sunderlal were sufficient to cause death in the normal course. Consequently, the homicide was a culpable homicide. Applying the law laid down in Virsa Singh it is clear that Ghasi and Lala are guilty of the murder of Sunderlal, the offence falling Under Section 300 (thirdly) of the Indian Penal Code and punishable Under Section 302 of the Indian Penal Code.

IN THE SUPREME COURT OF INDIA

Criminal Appeal No. 341 of 2005

Decided On: 04.07.2014

 Richhpal Singh Meena Vs. Ghasi

Hon'ble Judges/Coram:Ranjana Prakash Desai and Madan B. Lokur, JJ.

Citation: AIR2014SC3595, 2014CriLJ4339, 2014(4)RCR(Criminal)61, 2014(8)SCALE193, (2014)8SCC918

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