In a significant judgment delivered on February 17, 2026, the Gujarat High Court modified a life sentence awarded in a 2016 Mehsana stabbing case. The Division Bench held that the incident, though fatal, did not amount to murder under Section 302 of the Indian Penal Code (IPC), but fell within the scope of culpable homicide not amounting to murder.
The court partly allowed the appeal filed by the accused, altering his conviction and reducing his sentence.
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Background of the Case
The case dates back to June 20, 2016. The deceased, Govindbhai Rawal, was standing near his soda rickshaw on the service road close to Wide Angle Cinema in Mehsana when the accused, Shaileshbhai Rawal, arrived on a motorcycle.
According to the prosecution, what began as casual banter and exchange of words escalated quickly. The accused allegedly used abusive language referring to the deceased’s family members. When the deceased refused to respond in kind, tempers flared.
The accused then took out a folding knife from his pocket and inflicted multiple blows on the deceased’s stomach, chest, abdomen, shoulder, hands and neck. The injured man was first taken to Mehsana Civil Hospital and later shifted to Ahmedabad Civil Hospital, where he succumbed to his injuries eight days later.
The Sessions Court had convicted the accused under Section 302 IPC and sentenced him to life imprisonment.
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Evidence Before the Court
During the appeal, the High Court examined medical records, postmortem findings, recovery of the knife, and most importantly, the dying declarations recorded by two doctors.
The bench noted that when the deceased was admitted to the hospital, he was conscious and clearly named the accused as the person who had stabbed him.
“The statements recorded by the treating doctors assume paramount importance,” the court observed, adding that the dying declarations were consistent and reliable.
Medical evidence showed multiple deep stab wounds, including injuries that pierced the ribs and diaphragm. Doctors opined that some of the injuries were sufficient in the ordinary course of nature to cause death.
However, the complainant who was projected as an eyewitness turned hostile during trial.
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Court’s Observations on Intention
The central question before the bench was whether the act amounted to murder or culpable homicide not amounting to murder.
The court carefully analysed the distinction between Section 302 (murder) and Section 304 Part I (culpable homicide not amounting to murder).
The judges noted that the quarrel appeared to have erupted suddenly. There was no evidence of prior enmity or premeditation. The accused pulled out the knife during the heated exchange.
“The assault appears to have been triggered by a sudden quarrel,” the bench said, adding that the act was committed “under a wave of provocation and fury.”
At the same time, the court did not ignore the seriousness of the injuries. The blows were directed at vital parts of the body. The medical evidence clearly showed that the accused had knowledge that such acts were likely to cause death.
Yet, the court found that the prosecution had not conclusively established a deliberate and pre-planned intention to kill.
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Application of Law
Relying on established Supreme Court principles distinguishing murder from culpable homicide, the High Court held that the case fell under Section 304 Part I IPC.
The bench observed that though the injuries were grievous and sufficient to cause death, the overall circumstances - sudden fight, absence of pre-planning, heat of passion - brought the case outside the strict scope of Section 302.
“The absence of premeditation and the heat of passion arising from the sudden quarrel are significant,” the court stated.
Thus, while the accused was responsible for the fatal assault, the legal classification required modification.
Final Decision
The High Court partly allowed the appeal.
- The conviction under Section 302 IPC was altered to Section 304 Part I IPC.
- The life sentence was modified to rigorous imprisonment for 10 years.
- The fine and default sentence imposed by the Sessions Court were left unchanged.
- The accused is to be released only after completing 10 years of actual imprisonment from the date of arrest, if not required in any other case.
- Bail bonds were discharged.
With these directions, the appeal was disposed of.
Case Title: Raval Shaileshbhai Rameshbhai Virchandbhai v. State of Gujarat
Case No.: R/Criminal Appeal (Against Conviction) No. 1456 of 2018
Decision Date: 17 February 2026
