Legal Review and Analysis of Nandkumar @ Nandu Manilal Mudaliar vs State of Gujarat 2025 INSC 1302
In-Short
Case: Nandkumar @ Nandu Manilal Mudaliar vs State of Gujarat (2025 INSC 1302):The Supreme Court reclassified the offence from murder to culpable homicide not amounting to murder, holding that a sudden assault in a fit of anger, without premeditation, and where death occurs later due to sepsis, demonstrates knowledge but not the intention to kill, warranting conviction under Section 304 Part I IPC instead of Section 302 IPC.
1. Heading of the Judgment
Case Name: Nandkumar @ Nandu Manilal Mudaliar vs State of Gujarat
Citation: 2025 INSC 1302
Court: Supreme Court of India
Jurisdiction: Criminal Appellate Jurisdiction
Criminal Appeal No.: 1266 of 2014
Judges: Justice N.V. Anjaria and Justice K. Vinod Chandran
Date of Judgment: November 10, 2025
2. Related Laws and Sections
The judgment primarily interprets and applies the following sections of the Indian Penal Code, 1860 (IPC):
Section 299: Definition of 'Culpable Homicide'
Section 300: Definition of 'Murder'
Section 304: Punishment for culpable homicide not amounting to murder.
Section 304 Part I: Deals with acts committed with the intention of causing death, or with the intention of causing such bodily injury as is likely to cause death.
Section 304 Part II: Deals with acts committed with the knowledge that it is likely to cause death, but without any intention to cause death or such bodily injury.Section 302: Punishment for Murder.
Section 504: Intentional insult with intent to provoke breach of the peace.
3. Basic Judgment Details
This criminal appeal was filed by the convict, Nandkumar, challenging the judgment of the Gujarat High Court which had confirmed his conviction and life imprisonment sentence under Section 302 IPC (Murder) passed by the City Sessions Court, Ahmedabad.
The case of the prosecution was that on the night of June 13, 1998, the appellant went to the house of the deceased, Louis Williams, hurled abuses, and during the ensuing altercation, inflicted a stab injury with a knife on the victim's abdomen. The victim was hospitalized, underwent surgery, but developed septicemia and died 13 days after the incident. The appellant was convicted for murder by the trial court, which was upheld by the High Court.
4. Core Principle and Analysis of the Judgment
The Main Issue: Whether the act of the appellant amounted to 'murder' punishable under Section 302 IPC, or 'culpable homicide not amounting to murder' punishable under Section 304 IPC.
Supreme Court's Reasoning and In-depth Analysis:
The Supreme Court undertook a detailed analysis to distinguish between 'murder' (Section 302) and 'culpable homicide not amounting to murder' (Section 304). The core of the judgment revolves around the establishment of mens rea (guilty mind), specifically the distinction between intention and knowledge.
Distinction between Intention and Knowledge: The Court relied on precedents like Kesar Singh v. State of Haryana (2008) and Virsa Singh v. State of Punjab (1958) to elucidate the legal principles. It reiterated that:
For Murder under Section 300/302: The prosecution must prove that the accused had the intention to cause death, or the intention to cause such bodily injury as is sufficient in the ordinary course of nature to cause death.
For Culpable Homicide not amounting to Murder under Section 304: If the act is done with the knowledge that it is likely to cause death, but without the intention to cause death, it falls under Section 304 Part II. If there is an intention to cause an injury likely to cause death, but not the intention to cause death itself, it falls under Section 304 Part I.Application to the Present Case: The Supreme Court analyzed the facts of the case against this legal backdrop:
Nature of the Act: The Court acknowledged that the appellant used a knife and inflicted a serious injury on the victim's abdomen, which was sufficient in the ordinary course of nature to cause death. This indicated that the appellant possessed the knowledge that his act was likely to cause death.
Absence of Premeditation and Intention to Kill: However, the Court noted the sequence of events – a prior quarrel, the appellant going to the victim's house in a fit of anger, abusive language, and a sudden assault. This pointed towards impulse, anger, and sudden provocation. The Court concluded that there was no evidence of premeditation or a specific intention to kill the deceased. The act was not planned; it was a result of a sudden flare-up.
Delay in Death and Cause: The fact that the victim died 13 days after the incident due to "Septicemia" (a secondary infection) and not instantaneously, was considered a relevant, though not conclusive, factor in assessing the absence of an absolute intention to ensure death.
Conclusion of the Court on the Core Issue: The Supreme Court held that while the appellant had the knowledge that his act was likely to cause death, the prosecution failed to prove beyond reasonable doubt that he had the intention to cause death. Therefore, his act constituted "culpable homicide not amounting to murder" under Section 304 Part I of the IPC, and not murder under Section 302.
5. Final Outcome
The Supreme Court allowed the appeal partly and passed the following directions:
The conviction of the appellant under Section 302 IPC was set aside.
The conviction was converted to one under Section 304 Part I IPC.
The period of sentence of 14 years already undergone by the appellant was held to be sufficient and was deemed to serve the interest of justice.
The appellant's bail bond was discharged.
6. MCQs Based on the Judgment
1. In the case of Nandkumar @ Nandu Manilal Mudaliar vs State of Gujarat (2025 INSC 1302), the Supreme Court converted the conviction from Section 302 IPC to Section 304 Part I IPC primarily because?
a) The eyewitnesses were found to be unreliable.
b) The weapon used was not recovered.
c) The appellant had no knowledge that his act could cause death.
d) The appellant acted with knowledge but without the intention to cause death.
2. According to the Supreme Court's interpretation in the aforementioned judgment, what is the key distinguishing factor between an offence falling under Section 302 IPC and one falling under Section 304 Part I IPC?
a) The nature of the weapon used in the commission of the crime.
b) The time gap between the injury and the death of the victim.
c) The presence or absence of intention to cause death.
d) The number of injuries inflicted on the victim.
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