Ravinder v. State of India: Upholding Justice in a Landmark Murder Conviction Case

In a significant legal battle, the Supreme Court of India has rendered a crucial judgment in the case of Ravinder v. State of India. The case delves into the complex issue of culpable homicide amounting to murder, resulting from a tragic altercation that led to the death of an individual. This summary sheds light on the decisive proceedings and the final verdict that upholds justice in the face of adversity.


  • Anoop Kumar’s brother and father arrived at the scene during the incident.
  • Charge-sheet filed against all four accused persons, including one of the respondents.
  • Initial case under Sections 307, 504, 506/34 IPC later converted to Section 302 IPC after victim’s death.
  • Respondent No. 2 (original accused no. 1) appealed the conviction order before the High Court.
  • Accused persons were instructed to leave by Anoop Kumar’s family.
  • Vishnu Kumar, Rakesh Kumar, and Sudhir @ Ramaudh encouraged firing at the deceased.
  • Ravinder fired at the complainant’s mother with a country-made pistol.
  • Complainant took his injured mother to the police station and lodged an FIR.
  • Three accused persons were acquitted by the Trial Court.
  • Quarrel and confrontation occurred between the accused and the complainant’s mother during the incident.
  • The High Court modified the conviction from Section 302 IPC to Section 304 Part I IPC for Ravinder
  • Ravinder was sentenced to 10 years of rigorous imprisonment and a fine of 20,000/-
  • The modification in the conviction led to the original complainant filing an appeal

Also Read: Dispensation with Personal Appearance in Criminal Case: Landmark Judgement by Supreme Court of India


  • The original complainant’s Advocate argues that the accused coming with a firearm after an altercation and firing at the deceased from close range falls under Section 300 IPC, not Exception 4.
  • Citing the State of Madhya Pradesh v. Shivshankar case, it is argued that mutual provocation and blows from both sides are necessary for Exception 4 to apply.
  • Since there was no blow from the complainant’s side or the deceased, the Advocate asserts the case should not be under Exception 4 to Section 300 IPC.
  • The High Court’s conversion of the conviction to Section 304 Part I IPC is heavily contested as it is believed the case falls under Clause fourthly to Section 300 IPC, making it culpable homicide amounting to murder.
  • The accused’s Advocate contends that the High Court’s decision was justified as the crime was not planned and happened in the heat of the moment, and therefore, a lower charge is appropriate.
  • The learned Advocate representing the respondent argues that Exception 4 to Section 300 IPC is applicable in this case, justifying the conversion of conviction from Section 302 IPC to Section 304 Part I IPC.
  • The learned Advocate highlights that the Trial Court acquitted three other accused individuals, noting the absence of pre-planning or prior intention to commit the murder when Lajjawati went to complain to Ravinder.
  • The unchallenged finding of the Trial Court supports the application of Exception 4 to Section 300 IPC, further substantiating the conversion of the conviction as done by the High Court.

Also Read: The Jodha Ram vs. Kaushaliya Dispute: Supreme Court Judgement Summary


  • The High Court erred in converting the conviction from Section 302 IPC to Section 304 Part I IPC based on the grounds that it was not a planned crime and there was no prior intention.
  • The incident where the deceased was shot by Ravinder (accused No. 1) from close range did not involve further grave and sudden provocation.
  • The accused had used abusive language which led to the altercation, and the accused specifically mentioned not having fear due to a previous conviction.
  • Exception 4 to Section 300 IPC is only applicable in cases of fights or quarrels that involve mutual provocation and blows exchanged by both sides.
  • Intention to cause death is inferred in cases of intentional firing, unless falling under any exceptions.
  • The appellant in this case did not cause any injury to the deceased or his companions.
  • The deceased, who was unarmed, suffered three fatal injuries inflicted by the appellant using an axe.
  • As the appellant used a formidable weapon on an unarmed victim and did not meet the criteria of mutual provocation, Exception 4 is not applicable in this case.
  • The case falls under Clause fourthly to Section 300 IPC as the accused fired from a close range with a country-made firearm.
  • The accused’s act was imminently dangerous and likely to cause death or such bodily injury as is likely to cause death.
  • Observations made by the Trial Court in acquitting other accused cannot benefit the original accused who fired at the deceased from a close range.

Also Read: Contractor vs. FCI: Determination of Profit and Wage Dispute


  • The judgment convicting the original accused No 1 for the offence under Section 302 IPC is restored.
  • The High Court’s decision to modify the conviction to Section 304 Part I IPC is quashed and set aside.
  • The original accused No 1 is ordered to surrender before the concerned Court to serve the sentence imposed by the Trial Court within three months.


Case Number: Crl.A. No.-001670-001670 / 2019

Click here to read/download original judgement

Leave a Reply

Your email address will not be published. Required fields are marked *