The Delhi High Court has modified the conviction of a man sentenced to life imprisonment for the death of his friend during a drunken altercation, holding that the case did not amount to murder under Section 302 IPC.
A Division Bench of Justice Prathiba M. Singh and Justice Madhu Jain observed that the incident arose out of a sudden quarrel between two intoxicated friends over payment for liquor and lacked premeditation.
Background of the Case
According to the prosecution, Sanjay Singh and the deceased Amit were close friends who frequently consumed alcohol together. On February 29, 2020, Singh allegedly took Amit to his rented room in Bakkarwala, Delhi, where both consumed liquor.
The prosecution claimed that a dispute broke out over payment for the liquor. During the argument, Amit allegedly slapped Singh, after which Singh picked up a brick lying outside the room and repeatedly struck Amit on the head.
The landlord, Jai Bhagwan, testified that Singh later came to him in a disturbed condition and confessed that he had killed someone during a quarrel. When they reached the rented room, Amit was found lying in a pool of blood with a blood-stained brick nearby.
The Trial Court had convicted Singh under Section 302 IPC and sentenced him to life imprisonment with a fine of Rs. 50,000.
The High Court noted that the evidence clearly established Singh’s involvement in the incident. The Bench relied on forensic evidence, including DNA reports matching the deceased’s blood with stains found on the brick and the appellant’s clothes.
The Court also accepted the testimony of the deceased’s wife, who had last seen Amit leaving with Singh on the morning of the incident.
However, the Bench emphasized that the circumstances surrounding the incident showed absence of prior planning or intention to kill.
“The two men were friends. They were drinking together. The quarrel arose without warning over something as trivial as payment for a bottle of liquor,” the Court observed.
The Court further noted that the brick used in the assault was picked up from the spot itself and was not a weapon carried in advance, which indicated lack of premeditation.
Referring to Exception 1 to Section 300 IPC dealing with grave and sudden provocation, the Bench said the alleged slap by the deceased immediately before the assault could not be ignored in the factual context of the case.
The High Court held that while Singh had knowledge that repeated blows with a brick could likely cause death, the prosecution failed to establish a deliberate intention to commit murder.
“The present case would therefore fall within the ambit of Section 304 Part II IPC,” the Bench ruled.
Accordingly, the Court altered the conviction from Section 302 IPC to Section 304 Part II IPC and reduced the sentence from life imprisonment to rigorous imprisonment for eight years.
The fine imposed by the Trial Court was left unchanged.
Case Details
Case Title: Sanjay Singh v. State (NCT of Delhi)
Case Number: CRL.A. 622/2025
Judges: Justice Prathiba M. Singh and Justice Madhu Jain
Decision Date: May 20, 2026
