Maniklal Sahu v. State of Chhattisgarh, 2025
The ruling aligns with precedent, particularly decisions that emphasize the "proximate cause" test rather than requiring a direct and fatal injury.
Judgement Details
Court
Supreme Court of India
Date of Decision
19 September 2025
Judges
Justice Sanjiv Khanna & Justice Dipankar Datta
Citation
Acts / Provisions
Section 13(1)(ia), Hindu Marriage Act, 1955
Section 25, Hindu Marriage Act, 1955
Facts of the Case
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The appellant was convicted under Section 307 IPC for attempting to murder the victim by inflicting multiple injuries.
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During appeal, the key argument raised was that none of the individual injuries alone were fatal in the ordinary course of nature to cause death.
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However, the prosecution contended that the cumulative effect of the injuries inflicted was sufficient to cause death, and hence the conviction was valid.
Issues
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Whether the cumulative effect of injuries can be considered sufficient in the ordinary course of nature to cause death, even when none of the individual injuries are fatal?
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Whether the death (if it had occurred) due to complications would be legally attributed to the injuries inflicted?
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Whether the conviction under Section 307 IPC was justified based on the evidence and medical findings?
Held
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The Court upheld the trial court’s conviction under Section 307 IPC, ruling that:
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The cumulative nature of injuries was a valid ground to presume intent and knowledge.
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An intervening cause or later complication does not negate the initial intent or gravity of the injuries inflicted.
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The causal connection between the act and the probable death remained proximate and direct.
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Analysis
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The Court reiterated well-established principles regarding causation in criminal law when evaluating attempt to murder, courts must not focus only on individual injuries but also consider the combined effect.
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If the natural and probable consequences of the act are death or grievous injury, then Section 307 IPC is rightly attracted.
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The decision strengthens the jurisprudence around criminal intention and knowledge, especially when death is avoided by chance or medical intervention.
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The ruling aligns with precedent, particularly decisions that emphasize the "proximate cause" test rather than requiring a direct and fatal injury.