News Citation : 2026 LN (HC) 150 | 2026:CGHC:5212-DB
January 30, 2026 : The High Court of Chhattisgarh has modified the conviction of two men sentenced to life imprisonment in a 2017 murder case, holding that the evidence did not support a charge of murder but instead established grievous hurt that ultimately led to death.
In a judgment delivered on January 30, 2026, a Division Bench of Justice Sanjay K. Agrawal and Justice Arvind Kumar Verma partly allowed Criminal Appeal No. 136 of 2019 and set aside the conviction of Tulsi Satnami and his son Mahendra Kumar Satnami under Section 302 read with Section 34 of the Indian Penal Code. The Court instead convicted them under Section 325 read with Section 34 of the IPC and sentenced them to the period already undergone.
The case arose from a boundary dispute between neighbors in Village Dandgaon, District Mungeli. According to the prosecution, the incident occurred on June 28, 2017, when the two accused allegedly assaulted 62 year old Chandrika Bai with hands and fists. She died ten days later, on July 7, 2017.
The trial court had found them guilty of murder and sentenced them to life imprisonment along with a fine of Rs 5,000 each. Challenging that verdict, the appellants argued before the High Court that the medical evidence did not support a finding of murder.
The postmortem report, proved during trial, revealed that the deceased was suffering from cardiomegaly, or an enlarged heart, along with a left intraventricular blood clot. The doctor opined that the cause of death was syncope due to cardiomegaly and intraventricular clot, which led to shock and death. Notably, no significant external injuries were found on the body except swelling on the shoulder, which the medical evidence suggested could even be consistent with a honey bee sting.
The Bench examined whether the assault, consisting of blows with hands and fists, could be said to have been committed with the intention or knowledge required to sustain a conviction under Section 302 IPC. The Court noted that the deceased was already suffering from a serious heart condition and that the medical evidence did not indicate fatal external trauma directly attributable to the accused.
Referring to the Supreme Court’s decision in State of Karnataka v. Shivalingaiah, the High Court observed that whether an act amounts to murder or a lesser offence depends on the facts of each case, particularly on the presence of intention or knowledge that death is likely to result.
In the present case, the Court found that the assault stemmed from a sudden boundary dispute and there was no evidence to show that the accused intended to cause death or had knowledge that their actions were likely to cause it. However, the injury was considered serious enough to fall within Clause Eighthly of Section 320 IPC, which defines grievous hurt as hurt that endangers life.
Concluding that the act amounted to voluntarily causing grievous hurt under Section 325 IPC rather than murder, the Court acquitted the appellants of the charge under Section 302 IPC. Since both had already spent more than a year and a half in custody before being granted bail in 2019, the Bench sentenced them to the period already undergone. Their bail bonds were directed to remain in operation for six months in compliance with Section 437A of the Code of Criminal Procedure.
With this ruling, the High Court clarified the distinction between murder and grievous hurt in cases where pre existing medical conditions significantly contribute to the cause of death.
Case Reference : CRA No. 136 of 2019, Tulsi Satnami and Another vs State of Chhattisgarh — For Appellants: Mrs. Laxmin Tondey, Advocate; For Respondent/State: Dr. Surendra Kumar Dewangan, Panel Lawyer.
