Case Law On Poisoning Offences
1. State of Rajasthan v. Kashi Ram, AIR 2006 SC 1446
Facts:
The accused was charged with murder by poisoning. The victim died due to ingestion of poison administered by the accused.
Judgment:
The Supreme Court upheld the conviction for murder, holding that poisoning is a dangerous weapon and that its administration with intent to kill attracts the charge of murder under Section 302 IPC.
Key Points:
Medical evidence and expert testimony on the poison’s nature are critical.
Poisoning with intent to kill establishes mens rea for murder.
Even if death is accidental but poison was administered knowingly, culpability stands.
2. Rajesh v. State of Haryana (2017) 11 SCC 272
Facts:
The accused was convicted for voluntarily causing hurt by poison under Section 324 IPC. The victim survived after being poisoned.
Judgment:
The Court held that when poison is administered with the intention to cause bodily pain or injury but not death, Section 324 applies. The injury caused by poison need not be fatal for conviction.
Key Points:
Distinction between Section 302 (murder) and Section 324 (hurt by poison) based on intention and outcome.
Severity of injury and intention to kill are decisive.
3. Vishnu v. State of Maharashtra, (2004) 12 SCC 491
Facts:
Accused was charged with abetment of suicide by poisoning his wife.
Judgment:
Supreme Court convicted the accused under Section 306 IPC, holding that coercion or harassment causing suicide is punishable. Administration of poison as a means of abetment was emphasized.
Key Points:
Suicide induced by mental torture, poisoning, or threat amounts to abetment.
The link between accused’s act and victim’s death must be established.
4. Mohan Lal v. State of Rajasthan, AIR 1963 SC 1369
Facts:
The accused allegedly administered poison to his wife, resulting in her death.
Judgment:
The Court discussed the principle of 'dangerous weapons', holding poison to be a deadly weapon. It emphasized the need for conclusive medical evidence linking poison administration to death.
Key Points:
Poison is treated on par with weapons like firearms.
Medical proof of cause of death by poison is essential.
5. Prem Singh v. State of Punjab, AIR 1967 SC 63
Facts:
Accused charged for attempt to murder by giving poison.
Judgment:
The Court held that attempt to cause death or grievous hurt by poison attracts punishment under Section 307 IPC, even if the victim survives.
Key Points:
Intention and knowledge of administering poison are crucial.
Attempt charges are sustainable if intent to kill is proved.
6. Sultan Singh v. State of Punjab, AIR 1965 SC 1001
Facts:
Accused convicted for voluntarily causing hurt by poison.
Judgment:
The Court held that poison administration with intent to cause bodily injury (not death) attracts Section 324 IPC. The use of poison as a weapon of hurt is dangerous and punishable.
Summary of Legal Principles in Poisoning Offenses:
| Principle | Explanation |
|---|---|
| Poison as a weapon | Poison is treated as a deadly or dangerous weapon under IPC. |
| Intention (mens rea) | Criminal liability depends on intent to kill or cause hurt. |
| Medical evidence crucial | Proof of poison administration and causation of injury/death essential. |
| Distinction of charges | Murder (Section 302) if death; hurt (Section 324/328) if injury. |
| Abetment via poison | Causing or abetting suicide by poisoning punishable under Section 306. |
Conclusion:
Poisoning offenses require careful judicial scrutiny of intention, medical evidence, and causation. Courts have consistently held poison as a lethal weapon attracting serious criminal liability whether or not the victim dies. The above cases form the backbone of Indian jurisprudence on poisoning crimes.
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