The Tripura High Court has modified a life sentence awarded to a 76-year-old man convicted of killing his wife, holding that the case was not one of murder but culpable homicide not amounting to murder. The Division Bench partly allowed the appeal and reduced the sentence to eight years of rigorous imprisonment.
The judgment was delivered on January 7, 2026, in a criminal appeal filed by Sri Bir Manik Jamatia against his conviction under Section 302 of the Indian Penal Code (IPC).
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Background of the Case
According to the prosecution, the incident occurred on September 17, 2020, at the couple’s home in Gomati district. The complainant alleged that his stepfather, Bir Manik Jamatia, had struck his mother, Amulya Rani Jamatia, on the head with a stick (lathi), resulting in her death.
An FIR was lodged the following day. After investigation, the police filed a charge sheet under Section 302 IPC, which deals with murder. The Sessions Court in Gomati convicted the accused in September 2022 and sentenced him to life imprisonment along with a fine of ₹10,000.
Challenging the conviction, the accused approached the High Court.
Arguments Before the Court
Counsel for the appellant argued that the entire case rested on an extra-judicial confession-meaning a confession made outside court-and that such evidence is considered weak unless strongly supported by other proof.
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It was also submitted that there were no eyewitnesses to the incident. Most witnesses had only spoken about what the accused allegedly told them after the incident. The defence further argued that the alleged confession made before the police was not recorded before a Magistrate under Section 164 of the Criminal Procedure Code, which weakened its evidentiary value.
The prosecution, on the other hand, maintained that several witnesses confirmed that the accused had admitted to striking his wife. The State also relied on the post-mortem report, which showed a head injury, and on the seizure of blood-stained clothes.
Court’s Observations on Evidence
After reviewing the depositions of 19 prosecution witnesses, the Bench noted that none of them had actually seen the assault take place.
“The extra-judicial confession must be accepted with great care and caution,” the Court observed, referring to settled legal principles. It emphasized that such a confession can form the basis of conviction only if it inspires confidence and is supported by a complete chain of circumstances.
The Court also noted that the alleged confession before the police was not recorded before a Magistrate. “Such a report has got no evidentiary value,” the Bench pointed out.
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However, the judges did not completely discard the prosecution’s case. They observed that witnesses consistently stated that there had been an altercation between the husband and wife on the day of the incident. The post-mortem report showed a single head injury caused by a blunt object.
Importantly, the Court highlighted that only one blow was inflicted.
“If the appellant had intention to kill his wife, he would not have inflicted a single blow that too with a stick,” the Bench noted.
Sudden Fight, No Premeditation
The Court took into account the strained relationship between the couple, as spoken about by multiple witnesses. There was evidence that quarrels between them were frequent and that village meetings had been held earlier to resolve disputes.
In the Court’s view, the fatal blow appeared to have been delivered during a sudden fight, in a moment of rage, rather than as a pre-planned act.
“There is nothing on record to demonstrate that the appellant had an intention to cause death,” the Bench held. It further observed that the act was committed “in the heat of the moment.”
Under criminal law, murder requires proof of intention to cause death or knowledge that the act is likely to cause death. The Court found that such intention was not clearly established in this case.
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Decision of the Court
Based on its analysis, the High Court converted the conviction from Section 302 IPC (murder) to Section 304 Part I IPC, which deals with culpable homicide not amounting to murder.
The life sentence was reduced to eight years of rigorous imprisonment. The Court directed that the period already undergone by the appellant be set off against the new sentence.
With this modification, the appeal was partly allowed and disposed of.
Case Title: Sri Bir Manik Jamatia vs State of Tripura
Case No.: Crl. A(J) 55/2024
Decision Date: 07 January 2026
