The Supreme Court on Thursday partly allowed appeals filed by three Haryana men convicted in a 2000 assault case, holding that the prosecution failed to prove the intention required for an offence of attempt to murder under Section 307 IPC.
A Bench of Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh altered the conviction to voluntarily causing grievous hurt under Section 325 IPC and reduced the sentence to the period already undergone by the appellants.
Background of the Case
The case arose from an incident dated June 5, 2000, in Haryana’s Rewari district. According to the prosecution, complainant Amar Singh, who was on village night-watch duty, reached a spot near Rama Nand’s house where some persons were allegedly assaulting another man.
When Amar Singh intervened, he was allegedly attacked with lathis by the accused persons. The prosecution claimed that he suffered serious head injuries and later required prolonged treatment in Delhi hospitals.
The trial court convicted Roshan Lal, Sajjan Singh and Satya Prakash under Sections 307 and 506 IPC, sentencing them to seven years’ imprisonment. The Punjab and Haryana High Court later upheld the conviction.
Before the Supreme Court, the appellants argued that there was no intention to kill the complainant and that the incident happened suddenly during a scuffle. They also questioned inconsistencies between the medical evidence and witness testimonies.
The Bench examined whether the ingredients of Section 307 IPC - particularly the intention or knowledge to commit murder - were established from the evidence on record.
Referring to earlier rulings, the Court reiterated that the seriousness of injuries alone is not enough to sustain a conviction for attempt to murder. The prosecution must also prove the accused acted with the intention or knowledge that their actions could cause death.
The Bench noted that the assault appeared to have occurred suddenly when Amar Singh intervened in an ongoing altercation. The Court found no evidence of prior enmity, planning, or a deliberate attempt to kill him.
“The assault, therefore, appears to have arisen in the heat of the moment,” the Bench observed while discussing the circumstances of the incident.
The Court further observed that ordinary lathis were used in the incident and there was no material showing repeated or exceptionally brutal attacks that would clearly indicate an intention to cause death.
At the same time, the Bench accepted the medical evidence showing that the complainant suffered fractures in both parietal bones and underwent prolonged treatment. The Court held that the injuries clearly amounted to “grievous hurt” under Section 320 IPC.
The Supreme Court ultimately altered the conviction from Section 307 IPC to Section 325 read with Section 34 IPC.
Considering the time already spent in custody by the three appellants during trial and appeals, the Court sentenced them to the period already undergone. However, it directed each appellant to pay a fine of ₹50,000 to the injured complainant. Failure to pay the amount would result in an additional six months of simple imprisonment.
Case Details:
Case Title: Roshan Lal v. State of Haryana
Case Number: Criminal Appeal Nos. 2207, 2209 & 2210 of 2011
Judges: Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh
Decision Date: May 22, 2026
