Supreme Court Converts Murder Conviction to Culpable Homicide — Land Dispute Fight Showed No Intention to Kill, Accused Released After 12 Years in Jail

Case Name: Raghav Prashad & Ors. v. State of U.P.
Date of Judgment: September 26, 2025
Citation: 2025 INSC 1172, Criminal Appeal No. 596 of 2014
Bench: Hon’ble Chief Justice B.R. Gavai and Hon’ble Mr. Justice K. Vinod Chandran

Held: The Supreme Court partly allowed the appeal, converting the appellants’ conviction from Section 302 IPC (murder) to Section 304 Part I IPC (culpable homicide not amounting to murder). It held that although the accused assaulted the deceased with sticks, pike, and spear, they had used the blunt side of the sharp weapons. The evidence showed knowledge that death could result but not intention to kill. Since the appellants had already undergone more than 12 years of imprisonment, the Court ordered their release, holding that the sentence already served would meet the ends of justice.

Summary: The case arose from a 1986 altercation over agricultural field measurement at Baruahaar Ghat, Banda. The complainant Ram Gopal (PW-1) and his family were attacked by accused Raghav Prashad, Prem Shankar, Dayanidhi, and Ram Naresh. Three victims, Ram Avtar, Namo Shankar, and Girija Shankar, later died of injuries. The trial court convicted the accused under Section 302 IPC and sentenced them to life imprisonment in 1989, which the Allahabad High Court affirmed in 2013. On appeal, the Supreme Court scrutinized the evidence: PW-1’s account confirmed use of blunt force rather than cutting injuries, corroborated by medical reports showing only lacerated and contused wounds, not incised wounds. PW-2 had turned hostile, and there was prior enmity over land measurement. The Court concluded that intention to kill was not established, though knowledge of likely fatal injuries existed, fitting the offence under Section 304 Part I IPC.

Decision: The Supreme Court converted the conviction from Section 302 to Section 304 Part I IPC. Since the appellants had already served more than 12 years, the Court directed their immediate release unless required in another case.