Palani Goundan vs Emperor
51IND.CAS.164
Case Summary
[Culpable Homicide]
Facts
The accused, Palani Goundan, was convicted for the murder of his wife. Evidence showed that on October 23, 1918, the deceased was seen crying after being beaten by the accused. Later that evening, her body was found in the accused’s house, lying on the floor with a ploughshare nearby. The medical examination revealed a severe head injury that would have rendered her unconscious, followed by death by strangulation, likely caused by hanging.
The accused claimed that he found his wife hanging and called witnesses to support his story, but their evidence was inconsistent. The prosecution argued that the accused, believing his wife was already dead after striking her on the head, hanged her to stage a suicide.
Issues
Whether the accused’s actions constitute murder under Section 300 of the Indian Penal Code (IPC).
Whether the accused intended to cause the death or the bodily injury sufficient in the ordinary course of nature to cause death.
Whether the act of hanging, assuming the deceased was already unconscious, qualifies as culpable homicide amounting to murder.
Key Legal Provisions
Section 299 IPC: Defines culpable homicide and includes causing death by an act intended to cause bodily injury likely to result in death.
Section 300 IPC: Specifies conditions under which culpable homicide amounts to murder, particularly when:
The act is done with the intention of causing death, or
The act is done with the intention of causing bodily injury sufficient to cause death in the ordinary course of nature.
Judgement
The court determined that the accused inflicted a head injury that rendered the deceased unconscious and then hanged her. The hanging was deemed an intentional act to conceal the prior assault, not constituting an act of bodily injury sufficient to cause death.
The court held him liable for only grievous hurt and not culpable homicide.
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