Summary and Analysis of Maniklal Sahu vs State of Chhattisgarh 2025 INSC 1107

1. Heading of the Judgment

Criminal Law – Causation in Homicide Cases – Delayed Death Due to Medical Complications – Applicability of Section 302 vs. Section 307 IPC

Citation: Maniklal Sahu v. State of Chhattisgarh, 2025 INSC 1107 (Supreme Court of India, decided on 12.09.2025).

2. Relevant Laws and Legal Provisions

• Indian Penal Code, 1860 (IPC):
  Section 299: Culpable Homicide
  Section 300: Murder
  Section 302: Punishment for Murder
  Section 307: Attempt to Murder

• Explanation 2 to Section 299 IPC: Deems a person to have caused death even if timely medical treatment could have prevented it.

3. Basic Details of the Case

• Parties:
  Appellant: Maniklal Sahu (convict-accused)
  Respondent: State of Chhattisgarh

• FIR No.: 0061 of 2022, Saja Police Station, Bemetara, Chhattisgarh

• Trial Court: Convicted under Section 302 IPC (murder) and sentenced to life imprisonment.

• High Court: Altered conviction to Section 307 IPC (attempt to murder) and sentenced to 7 years RI.

• Supreme Court: Dismissed the appeal, but strongly disapproved the High Court’s reasoning and clarified the law on causation.

4. Explanation of the Judgment

Factual Background

• On 22 February 2022, the appellant and three others trespassed into the house of Rekhchand Verma, dragged him to the terrace, threw him down, and assaulted him with sticks.

• The victim was admitted to the hospital in a critical condition. He survived for about nine months and died on 8 November 2022 due to septic shock, bilateral pneumonia, post-traumatic spinal cord injury, paraplegia, and infected bedsores.

• The trial court convicted all accused under Section 302 IPC. The High Court altered the conviction to Section 307 IPC, citing the long survival period and alleged lack of proper treatment.

Key Issues

1. Whether the offence falls under Section 302 IPC (murder) or Section 307 IPC (attempt to murder)?

2. Whether the delayed death due to medical complications breaks the chain of causation?

3. Whether the intention to commit murder can be inferred from the acts of the accused?

Supreme Court’s Analysis

a. Nature of Offence: Section 302 vs. Section 307 IPC

• The Court reiterated that Section 307 IPC applies when an act is done with the intention or knowledge that it would cause death, but death does not ensue.

• Section 302 IPC applies when death is caused with the intention or knowledge specified under Section 300 IPC.

• The Court emphasized that the interval between injury and death is not determinative. What matters is whether the injury was sufficient in the ordinary course of nature to cause death.

b. Doctrine of Causation

• The Court referred to Explanation 2 to Section 299 IPC, which states that a person is deemed to have caused death even if proper treatment could have prevented it.

• Medical complications like septicemia, pneumonia, or infection that naturally flow from the injury do not break the chain of causation.

• The Court cited several precedents:
  Prasad Pradhan v. State of Chhattisgarh (2023) 11 SCC 320: Death after 20 days did not reduce liability from murder to culpable homicide.
  Jagtar Singh v. State of Punjab (1999) 2 SCC 174: Septicemia resulting from injury does not absolve the accused.
  Sudershan Kumar v. State of Delhi (1975) 3 SCC 831: Death due to acid burns after 12 days was held to be murder.

c. Intention and Knowledge

• The Court outlined factors to infer intention:
  Nature of weapon used.
  Part of the body injured.
  Severity of injuries.
  Conduct of the accused.

• In this case, the injuries were on the head and spine, inflicted with sticks, and were sufficient to cause death in the ordinary course of nature.

• The High Court erroneously considered the long survival period and alleged lack of treatment as grounds to reduce the offence to attempt to murder.

d. Medical Evidence

• Three doctors (PWs 9, 24, 28) consistently testified that the death was due to complications arising directly from the spinal injury caused during the assault.

• The post-mortem report (Ex. P-34) confirmed septic shock, pneumonia, and multi-organ failure as direct consequences of the injuries.

• There was no evidence to suggest that the treatment was inadequate or that any supervening cause broke the chain of causation.

e. Supreme Court’s Directions

• The Court laid down broad principles for similar cases:
  If the injury is fatal and intended to cause death, delayed death due to complications does not reduce the offence from murder.
  If the injury is sufficient in the ordinary course of nature to cause death, it is murder under Clause 3 of Section 300 IPC.
  The possibility of prevention through medical treatment is irrelevant.
  The chain of causation remains intact if complications are a natural and probable consequence of the injury.
  The court must examine whether the injury was the proximate cause of death, not the time lag.

Conclusion

• The Supreme Court upheld the conviction under Section 307 IPC (as the State did not file an appeal), but strongly criticized the High Court’s reasoning.

• The Court clarified that the offence should have been under Section 302 IPC, as the injuries were intended and sufficient to cause death, and the complications were a direct result.

• The appeal was dismissed.