High Court of Delhi (coram Prathiba M. Singh & Madhu Jain, JJ.; oral opinion by Madhu Jain, J.), 9 February 2026 — Four appeals under S. 415(2) BNSS against conviction under S. 302/34 IPC and life sentence (ASJ FTC-02, Tis Hazari, in Sessions Case 28476/2016 / FIR 224/2015, P.S. Darya Ganj) for the fatal beating of a motorcyclist in a sudden road-rage quarrel near Turkman Gate. Post-mortem showed blunt-force internal injuries (subarachnoid haemorrhage; liver lacerations involving about 30% of the liver with ~150 ml bleeding) but also severe pre-existing coronary artery disease (heart enlarged to ~400 grams; 100% right coronary and 80% left anterior blockage; evidence of a prior healed myocardial infarction). Held: (i) the occurrence was an unpredictable quarrel with fist and leg blows only, no weapon used or recovered, and no prior animosity; (ii) the testimonies of PW-7 and PW-9, claiming independent arrival at the spot, were improbable and unusable without corroboration; (iii) given the contributory cardiac condition, it could not be conclusively established that the injuries by themselves were sufficient to cause death in the ordinary course of nature, so the ingredients of S. 302 IPC were not attracted (following Maniklal Sahu v. State of Chhattisgarh, 2025 SCC OnLine SC 1960); (iv) the case equally fell outside S. 304 IPC for want of intention and knowledge of the pre-existing condition (relying on Nandkumar v. State of Gujarat, 2025 SCC OnLine SC 2374; noting Sompal Singh v. State of U.P., (2014) 7 SCC 316); (v) applying S. 320(8) IPC, the hurt was grievous as 'hurt which endangers life', on the analogy of Mayandi v. State, (2010) 11 SCC 774 (where S. 302 was altered to S. 326 for a deceased with an unknown heart ailment). Conviction altered to S. 325 read with S. 34 IPC (maximum seven years); appellants, having undergone roughly three years eight to ten months, were sentenced to time served and ordered released forthwith; bail and surety bonds discharged.
