Laxmaniya Yadav Vs State of Chhattisgarh — Murder and Culpable Homicide | Chhattisgarh HC (2026)

Partly allowed¶144

Laxmaniya Yadav v. State of Chhattisgarh

Chhattisgarh HC19 Apr 2026CRA/602/2024

Case brief

AI extract

What is this about?

Chhattisgarh High Court DB criminal appeal CRA 602/2024, Laxmaniya Yadav (accused/appellant) v. State of Chhattisgarh (PS Shankargarh, Balrampur-Ramanujganj), decided 20.04.2026 by Ramesh Sinha CJ and Ravindra Kumar Agrawal J. Murder conviction under Section 302 IPC altered to culpable homicide not amounting to murder under Section 304 Part-I IPC (RI 10 years) on Exception 4 to Section 300 IPC - sudden fight, no premeditation, heat of passion, no undue advantage or cruelty; conviction under Section 201 IPC and Sections 4 & 5 Chhattisgarh Tonahi Pratadna Nivaran Adhiniyam 2005 affirmed; partly allowed. Victim Munia Yadav killed 30.12.2020 by stone and axe blows to the head; eyewitnesses Sedgo Yadav PW-1 (husband) and Manoj Yadav PW-2 (son); postmortem Dr. Santu Bagh PW-8 (head injuries, homicide); FIR Ex.P-13 by Inspector Umesh Baghel PW-10; merg intimation Ex.P-11 by SI Pushpa Tirkey PW-9. Doctrine discussed: intention versus knowledge, Section 299/300/304 IPC, single-injury cases, sentencing factors. Precedents: Basdev v. State of Pepsu (AIR 1956 SC 488); Sukhbir Singh v. State of Haryana ((2002) 3 SCC 327); Gurmukh Singh v. State of Haryana ((2009) 15 SCC 635); State v. Sanjeev Nanda ((2012) 8 SCC 450); Arjun v. State of Chhattisgarh ((2017) 3 SCC 247) citing Surinder Kumar v. UT Chandigarh ((1989) 2 SCC 217) and Arumugam v. State ((2008) 15 SCC 590); Rambir v. State (NCT of Delhi) ((2019) 6 SCC 122); Anbazhagan (Criminal Appeal No.2043 of 2023, SC, 20.07.2023). Statutes: S.374(2) and S.313 CrPC 1973; Sections 302, 201, 300 (Exception 4), 304 Part-I/Part-II IPC. Appellant in jail since 16.01.2021; I.A.No.03/2024 for suspension of sentence disposed.

What the court decided

AI extract

Outcome

Appeal partly allowed to the extent indicated: conviction and sentence under Section 302 IPC set aside and altered/converted to conviction under Section 304 Part-I IPC with RI for 10 years; conviction and sentence under Section 201 IPC and Sections 4 & 5 of the Adhiniyam, 2005 affirmed; the appellant, in jail since 16.01.2021, to serve out the remaining sentence as modified; I.A.No.03/2024 (suspension of sentence/bail) stands disposed of.

Issue for consideration

Whether the death of deceased Munia Yadav was homicidal in nature. +2 more

Court's answer

The trial Court's finding, particularly relying on the postmortem evidence of Dr. Santu Bagh (PW-8), that death of Munia Yadav was homicidal in nature (cause: head injuries) is a finding of fact based on the record, neither perverse nor contrary to record, and is affirmed.

Ratio / Principle

On the evidence of eyewitnesses Sedgo Yadav (PW-1, husband of the deceased) and Manoj Yadav (PW-2, son of the deceased), the trial Court rightly held that it is the appellant-accused who caused the injuries over the head of the deceased due to which she died; that finding is affirmed.

Key takeaways

'Intent' and 'knowledge' cannot be treated in equal terms; knowledge is one of the circumstances to be taken into consideration while inferring the requisite intent; where the evidence discloses no intention to cause death but clear knowledge that the acts were likely to cause death, the accused can be held guilty under the second part of Section 304 IPC.ratio¶62
The appellant assaulted Munia Yadav all of a sudden with an axe causing grievous head injuries resulting in death; there was no premeditation, the act being committed out of anger and in the heat of passion; the case falls within Exception 4 to Section 300 IPC as all four essential ingredients are satisfied (sudden fight; no premeditation; heat of passion; no undue advantage or cruel or unusual manner), the appellant being deemed to have knowledge and intention that the injuries were likely to cause death.ratio¶139

Detailed headnote1 paragraphs

CRA No. 602 of 2024 | Laxmaniya Yadav v. State of Chhattisgarh | High Court of Chhattisgarh at Bilaspur (DB: Ramesh Sinha, Chief Justice, author; Ravindra Kumar Agrawal, J) | Decided 20.04.2026. Criminal appeal under S.374(2) CrPC against judgment of conviction and order of sentence dated 2.1.2024 of the Second Additional Sessions Judge, Ramanujganj (Sessions Case No.74/2021), convicting the appellant under Sections 302 & 201 IPC and Sections 4 & 5 of the Chhattisgarh Tonahi Pratadna Nivaran Adhiniyam, 2005 (imprisonment for life and fines). Held: (i) death of Munia Yadav was homicidal (postmortem by Dr. Santu Bagh, PW-8 - head injuries; haemorrhage and shock; homicide) - affirmed; (ii) eyewitnesses Sedgo Yadav (PW-1, husband) and Manoj Yadav (PW-2, son) established that on 30.12.2020 the appellant struck the deceased on the back of the head with a stone and inflicted axe blows - affirmed. Applying the Exception 4 to Section 300 IPC requirements (sudden fight; no premeditation; heat of passion; no undue advantage or cruelty) drawn from Basdev, Sukhbir Singh, Gurmukh Singh, Sanjeev Nanda, Arjun, Rambir and Anbazhagan (Supreme Court), the assault was held sudden, in anger and heat of passion, without premeditation: conviction under Section 302 IPC set aside and altered to Section 304 Part-I IPC with RI for 10 years; convictions under Section 201 IPC and Sections 4 & 5 of the Adhiniyam, 2005 affirmed. Appeal partly allowed; I.A.No.03/2024 disposed of; appellant (in jail since 16.01.2021) to serve the remaining sentence as modified.