The Karnataka High Court has converted a husband’s murder conviction into culpable homicide not amounting to murder after finding that he slapped his wife during a quarrel, causing her to fall and sustain fatal head injuries. The Court held that the medical evidence did not establish that the injury was sufficient, in the ordinary course of nature, to cause death, although the husband knew that his act was likely to cause death.
A Division Bench of Justice Mohammad Nawaz and Justice B. Pramod delivered the judgment on September 29, 2026, partly allowing the husband’s appeal and sentencing him to 10 years of rigorous imprisonment under Section 304 Part II of the Indian Penal Code (IPC).
Background
Anjaneyalu and his wife, Nandini, had married for love and had two children. According to the prosecution, Anjaneyalu repeatedly pressured Nandini to return to work despite her thyroid condition and had allegedly assaulted her in an earlier incident.
On April 1, 2016, a quarrel broke out between the couple at their residence in Doddaballapura, Karnataka. Nandini fell unconscious and was taken to a hospital, where she was declared dead.
The trial court convicted Anjaneyalu under Sections 498A and 302 IPC, sentencing him to one year’s imprisonment for cruelty and life imprisonment for murder. He challenged the decision before the High Court, arguing that his wife’s existing thyroid and heart conditions could have caused her to fall.
The High Court examined the post-mortem report, which recorded swelling on the left side of Nandini’s head, a deep cut above her right eyebrow and bruising around her right eye. The doctor attributed her death to cardiorespiratory arrest following a severe traumatic impact to the head.
The Bench also considered the testimony of a witness who stated that Anjaneyalu had told her he assaulted Nandini during the quarrel and that she subsequently fell. The Court rejected the defence theory that her injuries were caused merely by a fall arising from her medical condition.
However, the judges distinguished the circumstances from those required to sustain a murder conviction. The prosecution had not alleged the use of a weapon, and the medical evidence did not establish that the head injury was sufficient in the ordinary course of nature to cause death.
The Court observed:
“The above material on record goes to show that the incident took place in a quarrel and in the said quarrel, the accused slapped the deceased, as a result of which she fell down. As per medical evidence, the deceased has sustained a swelling over the left temporo parietal region. The evidence of PW.5 does not reveal that the said injury was sufficient in the ordinary course of nature to cause death. However, the accused had the knowledge that the said act committed by him was likely to cause the death. Hence in our considered view, the act committed by the accused would amount to culpable homicide not amounting to murder, punishable under Section 304 Part-II of IPC.”
The High Court partly allowed the appeal, set aside the conviction under Section 302 IPC and convicted Anjaneyalu under Section 304 Part II IPC. It sentenced him to 10 years of rigorous imprisonment and imposed a fine of ₹10,000, with six months of simple imprisonment in default of payment.
The Court upheld his conviction and sentence under Section 498A IPC for cruelty. It also maintained the existing directions concerning victim compensation and ordered both sentences to run concurrently.
Case Details
- Case Title: Anjaneyalu v. State of Karnataka
- Case Number: Criminal Appeal No. 398 of 2021 (C)
- Judges: Justice Mohammad Nawaz and Justice B. Pramod
- Decision Date: September 29, 2026
