The Delhi High Court has set aside the conviction of four men for murder in a decade-old road rage case from Turkman Gate, holding that the prosecution failed to establish the ingredients of murder or culpable homicide, and the case instead amounted to grievous hurt under the Indian Penal Code (IPC).
A Division Bench of Justice Prathiba M. Singh and Justice Madhu Jain overturned the trial court’s finding under Section 302 read with Section 34 IPC and converted the conviction to one under Section 325 IPC, sentencing the appellants to the period of imprisonment already undergone and directing their immediate release.
The case arose from an April 2015 incident in which a minor traffic collision between a motorcycle and a car escalated into a physical altercation, resulting in the death of a person. The trial court had convicted the accused on the basis of eyewitness testimony, holding that the group assault caused fatal injuries sufficient to constitute murder.
Reassessing the evidence, the High Court noted that the incident was a sudden road rage altercation without premeditation, use of weapons, or prior animosity. While acknowledging that the deceased suffered serious internal injuries, including head trauma and liver laceration, the Court placed significant reliance on medical evidence showing that the deceased had severe pre-existing coronary artery disease, including complete arterial blockage, which materially contributed to his death.
The Bench held that the medical record weakened the direct causal link between the assault and the death, making it unsafe to conclude that the injuries were sufficient in the ordinary course of nature to cause death or that the accused had the requisite intention or knowledge necessary for offences under Sections 302 or 304 IPC. The Court also expressed doubt over the natural presence and reliability of some prosecution witnesses.
Concluding that the injuries nonetheless amounted to “hurt which endangers life” within the meaning of Section 320(8) IPC, the Court held the appellants guilty of grievous hurt, noted that they had already spent nearly three years in custody, and ordered their release.
Appearances
Appellants- Mr. Abhijat Bal, Sr. Advocate with Ms. Nusrat Hossain, Mr. Manish Kumar Singh, Mr. Shantanu Mishra, Mr. Satyam Gupta, Mr. Harsh Vardhan, Advocates Ms. Nusrat Hossain, Mr. Manish Kumar Singh, Mr. Shantanu Mishra, Advs.
Respondent- Mr. Ritesh Kumar Bahri, APP with Ms. Divya Yadav & Mr. Lalit Luthra, Advs. Insp. Subhash Chand, PS Darya Ganj
