In a judgment that revisited a village clash from the early 1990s, the Supreme Court of India on Thursday upheld the conviction of an elderly man for culpable homicide but reduced his sentence to the period he has already spent behind bars. The court noted the absence of premeditation, the nature of the group fight, and the appellant’s advanced age while closing the long-running criminal appeal.
Background of the Case
The case dates back to December 1992 in Dudankhedi village of Madhya Pradesh. A quarrel broke out after a complaint over an earlier scuffle between two children. What began as a heated exchange soon escalated into a group clash involving lathis and axes.
Read also:- Supreme Court Rules Dumpers, Excavators Not ‘Motor Vehicles’; Gujarat Road Tax Demand Quashed
Ram Singh, who went to question his neighbour, suffered head injuries during the fight and later died while undergoing treatment. Multiple people from both sides were injured, and cross-cases were registered at the local police station.
Following a trial, the Sessions Court convicted Shrikrishna, among others, for murder and related offences, sentencing him to life imprisonment. On appeal, the High Court altered the conviction to culpable homicide not amounting to murder under Section 304 Part II of the IPC and imposed a seven-year rigorous imprisonment term with a fine.
Shrikrishna then approached the Supreme Court, challenging both the conviction and sentence.
The Bench closely examined eyewitness accounts, medical evidence, and the surrounding circumstances of the incident. Doctors confirmed that Ram Singh died due to a head injury caused by a hard and blunt object, consistent with a lathi blow.
Read also:- Every Marital Dispute Is Not Cruelty: Karnataka High Court Quashes 498A, Dowry Case Against Husband’s Family
However, the court also took note of the fact that the incident arose suddenly, without planning, and involved a free fight between two groups. Importantly, the appellant himself had suffered head injuries and had lodged a cross-complaint, claiming he acted in self-defence.
“The evidence points to a sudden clash where tempers flared on both sides,” the court observed, adding that it was difficult to infer a common intention to kill.
Court’s Observations
The Supreme Court agreed with the High Court that the ingredients of murder under Section 302 IPC were not made out. There was no proof of premeditation or a shared object to commit murder.
At the same time, the Bench held that the individual act of the appellant-striking a blow on the head-could not be ignored. “A blow on a vital part like the head carries with it the knowledge that it is likely to cause death,” the court said, explaining why Section 304 Part II was the appropriate offence.
The judges also highlighted that rioting and unlawful assembly charges failed, as the prosecution could not establish a common object among the accused.
Read also:- Every Marital Dispute Is Not Cruelty: Karnataka High Court Quashes 498A, Dowry Case Against Husband’s Family
Decision of the Court
While affirming the conviction under Section 304 Part II, the Supreme Court took a humanitarian view on sentencing. The Bench noted that Shrikrishna is now over 80 years old and has already spent more than six years in custody over different phases of the case.
“Sending him back to prison at this stage would be harsh and inadvisable,” the court remarked, reducing the sentence to the period already undergone.
With this modification, the criminal appeal was dismissed, bringing an end to a case that had travelled through the justice system for more than three decades.
Case Title: Shrikrishna vs State of Madhya Pradesh
Case No.: Criminal Appeal No. 1533 of 2011
Decision Date: 9 January 2026
