The Madras High Court acknowledged that the assault was not premeditated and modified the conviction from Section 302 (murder) to Section 304 Part I (culpable homicide not amounting to murder)
Dated: 23/ 08 / 2023
CORAM : THE HONOURABLE MRS. JUSTICE R.HEMALATHA
Crl.A.No.66 of 2022
Factual Background:
The case of Murugesan vs. State revolves around the conviction of the appellant, Murugesan, for an offence under Section 304(i) of the Indian Penal Code (IPC). The incident involves the assault of Murugesan’s wife, Muniyammal, which ultimately led to her death. The case sheds light on issues of domestic violence, alcoholism, and the assessment of intent in criminal acts.
Murugesan and Muniyammal were a married couple, residing together despite their strained relationship. The accused, Murugesan, was known to be an alcoholic and was often involved in altercations with his wife. The incident occurred when Murugesan, in an inebriated state, assaulted Muniyammal with an iron rod, causing severe head injuries. Muniyammal was taken to various hospitals but succumbed to her injuries, leading to the filing of a criminal case against Murugesan.
Trial and Conviction:
During the trial, the prosecution presented evidence through witnesses, including the victim’s children and brother, who testified about the accused’s violent behaviour and the events leading up to the assault. The prosecution also introduced medical reports and forensic evidence, which indicated the presence of the victim’s blood on the iron rod used in the assault. The accused, on the other hand, denied any involvement and claimed innocence.
The trial court convicted Murugesan under Section 304(i) IPC, which deals with culpable homicide not amounting to murder, and sentenced him to ten years of rigorous imprisonment along with a fine. The court considered factors such as the accused’s alcoholism, history of violence, and the nature of the assault in reaching its decision.
Key Issues and Legal Analysis:
Causation and Intent: The primary issue in this case is whether Murugesan had the intent to cause the injuries that led to his wife’s death. The court analyzed the evidence to determine whether the act was intentional, taking into account the history of domestic violence and the nature of the injuries inflicted.
Witness Testimonies: The court relied on the testimonies of key witnesses, including the victim’s children and brother, to establish the sequence of events and the accused’s behaviour. The prosecution successfully argued that these witnesses’ consistent narratives provided a clear picture of the events leading to the assault.
Forensic Evidence: The presence of the victim’s blood on the iron rod indicated that it was used as the weapon in the assault. This forensic evidence further supported the prosecution’s case against the accused.
Alcoholism and Violence: The court took note of the accused’s history of alcoholism and violent behaviour, which contributed to the strained relationship between him and his wife. This history provided context for the assault and highlighted the volatile nature of their domestic environment.
Court’s Decision and Observations:
The court recognized the prevalence of domestic violence and alcoholism, which often lead to tragic incidents within families. It emphasized the need for society to address these issues and promote gender equality. The court noted that while education and literacy have improved, certain societal problems continue to persist.
The court acknowledged that the assault was not premeditated and that it occurred in the heat of the moment. As a result, the court modified the conviction from Section 302 (murder) to Section 304 Part I (culpable homicide not amounting to murder). It sentenced the accused to seven years of rigorous imprisonment and imposed a fine.
Conclusion:
The case of Murugesan vs. State underscores the importance of addressing issues like domestic violence, alcoholism, and gender inequality within society. The court’s decision reflects a nuanced understanding of the circumstances surrounding the assault and highlights the need for a balanced approach to justice. This case serves as a reminder of the complexities involved in assessing intent, particularly in cases involving domestic violence and impulsive acts.
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Written by- Shreeya S Shekar