In a courtroom that felt unusually tense for a Monday morning, the Supreme Court on 10 November 2025 delivered a significant ruling by partially overturning the conviction of Nandkumar @ Nandu Manilal Mudaliar. The bench, comprising Justice K. Vinod Chandran and Justice N.V. Anjaria, held that the circumstances surrounding the 1998 stabbing incident did not fully satisfy the legal definition of "murder," prompting a shift of the conviction from IPC Section 302 (murder) to Section 304 Part I (culpable homicide not amounting to murder).
Background
The roots of the case go back to a quarrel on the evening of 12 June 1998. According to the prosecution narrative recorded by the trial court and noted by the Supreme Court, a heated fight between the appellant and his brother escalated when Rajesh nephew of the eventual victim Louis Williams intervened. In that moment of impulsive violence, Rajesh suffered knife injuries but no complaint was lodged, apparently because the family treated it as an internal dispute.
In the late hours past midnight, anger flared again. Witnesses stated that Nandkumar allegedly returned to Louis’ residence, abused him loudly and, amid the commotion, stabbed Louis on his abdomen and hand. Getting medical assistance at that hour proved difficult, and he was rushed to L.G. Hospital only after a neighbour helped with a rickshaw.
Louis underwent surgery, was discharged, then admitted again, eventually passing away on 26 June 1998 thirteen days after the assault. Doctors identified septicemia (a severe infection spreading through the bloodstream) as the cause of death. The police added the murder charge only after the death.
Court's Observations
While examining the appeal, the Supreme Court undertook a detailed review of medical evidence and witness statements in the record. The bench observed,
"The accused inflicted serious injuries, including one below the belly, and must be attributed with knowledge that such injuries could be fatal in the ordinary course of nature."
Yet, the Court simultaneously noted the emotional backdrop of the assault. Justice Anjaria remarked that the events unfolded in quick succession after an altercation involving close relatives. The bench observed, “There was an element of impulse, anger and self-provocation,” clarifying that these factors weakened the claim of premeditation usually essential to securing a murder conviction.
The judges also took note of the absence of an immediate fatal outcome. Louis did not die instantly; instead, complications during treatment led to septicemia. The Court stressed that this timeline indicated that although the injuries were serious, they might not have been inflicted with a definitive intention to kill.
The bench addressed arguments concerning witnesses being related to the deceased. It declined to discard their testimony solely on the basis of relationship, noting that consistency of statements and corroborative medical records made their depositions reliable.
Decision
After analysing all angles, the Supreme Court concluded that while the assault was undeniably violent, it did not bear the “special characteristics of murder” under Section 300 IPC. Instead, the act fitted the definition of culpable homicide not amounting to murder.
Therefore, the Court set aside the earlier conviction under Section 302 and substituted it with Section 304 Part I, which applies when an accused acts with knowledge that their actions could likely cause death but without intention to kill.
Since Nandkumar had already spent more than 14 years in jail, the Court held that the sentence served was sufficient.
"The sentence already undergone shall be treated as adequate and in the interest of justice," the bench ordered, directing discharge of the bail bond. With that, the appeal was allowed to the extent of modifying the conviction.
Case Title:- Nandkumar @ Nandu Manilal Mudaliar vs State of Gujarat
Case Number:- Criminal Appeal No. 1266 of 2014
