Rajasthan High Court Converts Murder Conviction to Manslaughter in Familial Tragedy

Laxman Das's life sentence reduced to seven years for killing son in heat of passion

In a significant judgment delivered by the Rajasthan High Court, the conviction of Laxman Das under Section 302 of the Indian Penal Code (IPC) was altered to Section 304 Part II IPC, reducing his sentence from life imprisonment to seven years of rigorous imprisonment. The Division Bench, comprising Justices Vinit Kumar Mathur and Anuroop Singhi, acknowledged the absence of premeditation, unstable mental condition, and familial context, which led to the tragic incident.

The case involved the appellant Laxman Das, a cobbler by profession, who was initially convicted of murder for the fatal assault on his son, Nishant Rathod. The incident occurred on June 29, 2017, when Laxman Das, in a fit of rage, attacked his sleeping son with a Nawala, a sharp-edged tool used by cobblers, causing a grievous injury to the neck. The son succumbed to his injuries after nearly a month of hospitalization.

During the trial, various witnesses, including family members, testified about Laxman Das's unstable temperament and his tendency to act impulsively. His wife, Jassi, and daughter, Mahima, both corroborated the appellant's mental instability and frequent quarrels within the family. The prosecution initially charged him under Section 302 IPC, leading to a life sentence.

However, upon appeal, the High Court revisited the circumstances surrounding the incident. The judgment emphasized the lack of intent to cause death, absence of prior enmity, and a single injury inflicted in the heat of passion. The court drew parallels with precedents such as "Gurmukh Singh v. State of Haryana" and "Kulwant Rai v. State of Punjab," wherein convictions were similarly altered due to spontaneous actions without premeditation.

Justice Mathur, delivering the judgment, stated, "In ordinary circumstances, no parent would cause fatal injury to their children. The appellant's actions, albeit tragic, stemmed from a moment of lost control rather than a deliberate intention to kill." The judgment reflects a nuanced application of sentencing principles, considering the gravity of the offense and the accused's mental state.

The court's decision to convert the conviction to culpable homicide not amounting to murder (Section 304 Part II IPC) resonates with the judiciary's approach to differentiate between murder and manslaughter in cases involving impulsive actions. Laxman Das's sentence now stands at seven years, with a fine maintained as imposed by the trial court.

This judgment underscores the importance of understanding the context of familial conflicts and mental health in criminal jurisprudence. It highlights the judiciary's role in balancing justice with compassion, ensuring sentences are proportionate to the nature and circumstances of the crime.

Bottom Line:

Conversion of conviction from Section 302 IPC to Section 304 Part II IPC based on absence of premeditation, unstable mental condition of the accused, and a single injury inflicted in heat of passion. 

Statutory provision(s): Indian Penal Code, 1860 Sections 302, 304 Part II; Section 374(2) Cr.P.C; Section 428 Cr.P.C

Laxman Das v. State, (Rajasthan)(DB) : Law Finder Doc Id # 2789931