Supreme Court Upholds Conviction Under Section 302 IPC for Murder in the Heat of Passion

Case Name: Surender Kumar v. State of Himachal Pradesh
Citation: 2025 INSC 1412
Date of Judgment/Order: 9th December 2025
Bench: Manoj Misra, Ujjal Bhuyan

Held: The Supreme Court upheld the conviction of Surender Kumar under Section 302 of the IPC, affirming that the act constituted murder and not a lesser offense like culpable homicide.

Summary: Surender Kumar was convicted under Section 302 IPC for the murder of the deceased, who was stabbed with four knife blows in a violent altercation. The appellant sought to reduce the charge to a lesser offense, citing the altercation that preceded the act. The Court examined the case under various exceptions to Section 300 IPC, including self-defense and sudden provocation, but found no evidence to support these claims. The Court concluded that the act was premeditated and committed in a cruel manner, rejecting the possibility of reducing the charge.

Decision: The appeal was dismissed, and the conviction under Section 302 IPC for murder was upheld. The Court found no mitigating factors to reduce the charge and dismissed the appellant’s plea for a lesser conviction