Legal Review and Analysis of Raghav Prashad and Others vs State of Uttar Pradesh 2025 INSC 1172
1. Heading of the Judgment
Raghav Prashad and Others vs. State of Uttar Pradesh (Criminal Appeal No. 596 of 2014
Citation: Raghav Prashad and Others vs. State of U.P., 2025 INSC 1172.
2. Related Laws and Sections
The judgment primarily interprets and applies the following sections of the Indian Penal Code, 1860 (IPC):
Section 302 IPC: Punishment for Murder.
Section 304 Part I IPC: Punishment for Culpable Homicide not amounting to Murder, where the act is done with the intention of causing death, or with the intention of causing such bodily injury as is likely to cause death.
Section 34 IPC: Acts done by several persons in furtherance of common intention.
3. Basic Judgment Details
Parties: Appellants - Raghav Prashad and Others; Respondent - State of Uttar Pradesh.
Forum: Supreme Court of India (Criminal Appellate Jurisdiction).
Bench: Chief Justice B.R. Gavai and Justice K. Vinod Chandran.
Appeal From: The judgment appealed against the order dated July 4, 2013, of the Division Bench of the High Court of Judicature at Allahabad.
Origin of Case: Sessions Case No. 88 of 1986 from the court of the Additional District and Sessions Judge, Karvi (Banda).
Final Outcome: Appeal was partly allowed.
4. Core Principle and In-Depth Analysis of the Judgment
The Central Legal Issue: Distinguishing Murder from Culpable Homicide
The core issue before the Supreme Court was not whether the appellants caused the deaths of the three deceased persons, but whether their actions constituted "murder" punishable under Section 302 IPC or a lesser offence of "culpable homicide not amounting to murder" under Section 304 Part I IPC. The Court was tasked with re-examining the evidence to ascertain the accused's intention (mens rea) at the time of the incident.
Analysis of Evidence and Judicial Reasoning
The Supreme Court conducted a meticulous analysis of the evidence on record, which formed the basis for its decision to alter the conviction:
Testimony of the Sole Eyewitness (PW-1): The prosecution case rested substantially on the evidence of PW-1, Ram Gopal, who was the son of one deceased and the nephew of the other two. While the appellants argued that he was a related witness, the Court did not outrightly reject his testimony. Instead, it closely scrutinized its contents. Crucially, PW-1's testimony revealed that although some accused were armed with sharp weapons (a pike and a spear), they had used only the blunt side of these weapons. This detail was pivotal.
Corroboration by Medical Evidence: The medical evidence (post-mortem reports) perfectly aligned with the ocular account. It showed that all three deceased had sustained "lacerated and confused wounds only and there were no incised wounds." The absence of any stab or cut wounds confirmed that the sharp-edged weapons were not used in a manner typically associated with an intention to kill.
Inference of Intention vs. Knowledge: The Trial Court and the High Court had convicted the appellants under Section 302 IPC, implying they found the intention to murder. However, the Supreme Court drew a finer distinction. The Court held that while the appellants certainly had the knowledge that their attack with blunt objects on vital parts could cause death (bringing the case under the second part of Section 299 IPC, which defines culpable homicide), the circumstances did not establish a specific intention to kill (required for murder under Section 300 IPC). The act was a violent assault arising from a sudden quarrel over a land dispute, not a premeditated killing.
The Supreme Court's Address and Final Holding
The Supreme Court affirmed the concurrent finding of the courts below that the appellants were responsible for causing the deaths. However, it disagreed with the legal classification of the offence. The Court held that the evidence pointed towards the offence falling under Exception 4 to Section 300 IPC (culpable homicide not amounting to murder in a sudden fight without premeditation).
Consequently, the Court exercised its power under Article 136 of the Constitution to do complete justice. It converted the conviction from Section 302 IPC to Section 304 Part I IPC. Regarding the sentence, noting that the appellants had already undergone over 12 years of imprisonment, the Court held that this period was sufficient to serve the interests of justice for the offence under Section 304 Part I IPC and ordered their immediate release.
5. Final Outcome of the Judgment
The Supreme Court passed the following order:
The appeal was partly allowed.
The conviction of the appellants was altered from Section 302 IPC to Section 304 Part I of the IPC.
The sentence of imprisonment already undergone by the appellants (over 12 years) was deemed sufficient, and they were directed to be released forthwith, if not required in any other case.
Questions (MCQs) Based on the Judgment
Question 1: In Raghav Prashad vs. State of U.P., the Supreme Court altered the conviction from Section 302 IPC to Section 304 Part I IPC primarily based on which key finding?
A) The main eyewitness (PW-1) was declared hostile.
B) The appellants had no prior enmity with the deceased.
C) The weapons were used in a blunt manner, indicating a lack of intention to kill.
D) The FIR was lodged under incorrect sections initially.
Answer: C) The weapons were used in a blunt manner, indicating a lack of intention to kill.
Question 2: The Supreme Court's decision in this case hinges on the critical distinction between?
A) Common intention and individual liability.
B) Related witness and independent witness.
C) Intention to kill and knowledge that the act may cause death.
D) Murder and accidental death.
Answer: C) Intention to kill and knowledge that the act may cause death.