The Supreme Court of India recently clarified the law on homicide, emphasizing that a delay in death doesn’t necessarily break the chain of causation if the original injury was fatal. If the original injury is of a fatal nature, it makes no difference that death is actually caused by a complication naturally flowing from the injury and not the injury itself, since the causal connection is proximate.
Justice J.B. Pardiwala, writing for the bench, emphasized -The presence of the supervening cause in the circumstances will not, in our view, alter the culpability. There had been no such considerable change of circumstances as to snap the chain of causation.
Here’s a breakdown of the key points:
Fatal Injury and Intention: If the injuries inflicted were intended to cause death and were fatal, it’s considered murder, even if death occurs after several days due to complications like septicaemia.
Nature of Injury: The court considers whether the complications leading to death were a natural, probable, or necessary consequence of the injury. If so, the injury is deemed to have caused death.
Irrelevance of Medical Treatment: The possibility that skilled medical treatment might have prevented the fatal result is irrelevant in determining whether the injury was sufficient to cause death.
Guidelines for Courts: The Supreme Court laid down guidelines for courts to follow in cases with delayed deaths:
Determine Causation: Courts must determine if the injury was the proximate cause of death.
Consider Intention and Nature of Injury: Courts should consider the intention behind the injury and its nature to determine culpability.
Attributable Supervening Causes: If supervening causes like infections are attributable to the injuries, the person inflicting the injuries is liable for causing death.
In a judgment that settles a vital question of criminal law concerning causation and delayed death, the Supreme Court of India held that the conviction for murder under Section 302 IPC must be restored where the injury inflicted was sufficient in the ordinary course of nature to cause death, even though the deceased succumbed to septicaemia and pneumonia nine months after the incident.
In the specific case of Maniklal Sahu v. State of Chhattisgarh, the Supreme Court ruled that the High Court erred in reducing the conviction from murder to attempt to murder due to a nine-month gap between the injury and death. The Supreme Court held that the causal chain remained intact since the complications were a direct result of the spinal injury.
The Supreme Court’s ruling clarifies that a delay in death doesn’t break the chain of causation if the original injury was fatal and intended to cause harm. This judgment emphasizes the importance of considering the nature and intention behind the injury, rather than just the timing of the death. The ruling provides crucial guidance for courts to determine culpability in cases with delayed deaths, ensuring justice is served based on the circumstances of each case.
