Dattatraya v. State of Maharashtra [2024] 2 S.C.R. 989
The Supreme Court of India, in Dattatraya v. State of Maharashtra (Criminal Appeal No. 666 of 2012, decided on February 1, 2024), addressed the conviction of Dattatraya for the death of his nine-month pregnant wife, Meenabai. The incident occurred during a sudden quarrel at their home, where the appellant, in an inebriated state, poured kerosene on his wife, resulting in fatal burn injuries. The trial court and the Bombay High Court had convicted him under Sections 302 (murder) and 316 (causing death of a quick unborn child) of the Indian Penal Code (IPC), sentencing him to life imprisonment and 10 years’ rigorous imprisonment, respectively.
Facts of the Case
On the night of January 26, 2007, Dattatraya returned home intoxicated and picked a quarrel with his wife while she was cooking.
In the heat of the moment, he poured kerosene on her, and as the stove burst, she suffered 98% burn injuries.
Meenabai, who was nine months pregnant, was taken to the hospital and gave a dying declaration implicating her husband.
Both Meenabai and her unborn child succumbed to their injuries.
Legal Issues
Whether the act constituted murder under Section 302 IPC or culpable homicide not amounting to murder under Section 304 Part II IPC.
The relevance of the sudden quarrel and absence of premeditation in determining the nature of the offence.
Arguments
Prosecution: Emphasized the brutality of the act and the dying declaration, arguing for conviction under Section 302 IPC.
Defence: Contended that the incident arose from a sudden quarrel without premeditation, and the accused lacked the intention to cause death, warranting a lesser charge under Section 304 Part II IPC.
Supreme Court’s Reasoning and Decision
The Court noted that the act was not premeditated but occurred in the heat of a sudden quarrel.
There was no evidence of prior intent to kill; the fatal act was a consequence of a spontaneous altercation.
The Court held that while the accused was aware his actions were likely to cause death, the absence of intent to kill or cause such bodily injury as is likely to cause death distinguished the case from murder.
The conviction under Section 302 IPC was therefore altered to Section 304 Part II IPC (culpable homicide not amounting to murder), and the sentence was reduced to ten years of rigorous imprisonment.
Since the appellant had already served over 13 years in jail, the Court ordered his immediate release.
Significance
This judgment underscores the distinction between murder and culpable homicide not amounting to murder, particularly in cases involving sudden quarrels without premeditation. The Court reaffirmed that the intention or knowledge behind the act is crucial in determining the appropriate charge and sentence.
Citation:
Dattatraya v. State of Maharashtra, [2024] 2 S.C.R. 989, Supreme Court of India, decided on 01 February 2024.
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