MANIKLAL SAHU versus STATE OF CHHATTISGARH

Citation: [2025] 10 S.C.R. 212 · Decided: 12-09-2025 · Supreme Court of India · Bench: J.B. PARDIWALA · Disposal: Dismissed

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Judgment (excerpt)

[2025] 10 S.C.R. 212 : 2025 INSC 1107
Maniklal Sahu 
v. 
State of Chhattisgarh
(Criminal Appeal No. 5578 of 2024)
12 September 2025
[J.B. Pardiwala* and R. Mahadevan, JJ.]
Issue for Consideration
Whether the High Court committed any error in bringing the case 
within the ambit of “attempt to commit murder” punishable u/s.307 
IPC on the ground that the deceased-R died after a period of nine 
months from the date of the incident.
Headnotes†
Penal Code, 1860 – First limb of s.300 – Fatal injury – 
Intention to cause death – Death occurs after several days of 
complications – Principle that Courts must remember:
Held: If it is proved that the injury was fatal and the intention was 
to cause death, though the death occurred after several days of 
septicaemia or other complications having supervened, yet it is 
undoubtedly a murder as it falls within the first limb of s.300 of 
the IPC. [Para 69(a)]
Penal Code, 1860 – Third limb of s.300 – Injuries sufficient 
to cause death in the ordinary course of nature – Intended 
injuries – Death occurs after complications – Principle that 
Courts must remember:
Held: If it is proved that the injuries by themselves were sufficient to 
cause death in the ordinary course of nature, and if it is established 
that those injuries were the intended injuries, though the death 
might have occurred after septicaemia or other complications had 
supervened, yet the act of the accused would squarely fall under 
the third limb of s.300 of the IPC and the accused is therefore 
liable to be punished u/s.302 of the IPC. [Para 69(b)]
* Author
[2025] 10 S.C.R. 
213
Maniklal Sahu v. State of Chhattisgarh
Penal Code, 1860 – Fourth limb of s.300 – Injuries imminently 
dangerous to life – Death occurs after complications – Principle 
that Courts must remember:
Held: If it is proved that the injuries were imminently dangerous 
to life, though the death had occurred after septicaemia or other 
complications had supervened, yet the act of the accused would 
squarely fall under the fourth limb of s.300 of the IPC, provided, the 
other requirements like knowledge on the part of the accused, etc. 
are satisfied and so the accused would be liable to be punished 
u/s.302 of the IPC – Here also, the primary cause of the death is 
the injuries and septicaemia. [Para 66(c)]
Penal Code, 1860 – s.300 – When injuries inflicted were 
sufficient in the ordinary course of nature to cause death – 
Relevancy of skilful and efficient medical treatment:
Held: In judging whether the injuries inflicted were sufficient in 
the ordinary course of nature to cause death, the possibility that 
skilful and efficient medical treatment might prevent the fatal result 
is wholly irrelevant. [Para 66(d)]
Penal Code, 1860 – s.300 – When the supervening causes 
are attributable to the injuries caused – Whether the person 
inflicting the injuries is liable for causing death:
Held: If the supervening causes are attributable to the injuries caused, 
then the person inflicting the injuries is liable for causing death, 
even if death was not the direct result of the injuries. [Para 66(e)]
Penal Code, 1860 – s.302 – The Courts to distinguish two types 
of cases i.e. first where the intervening cause of death, like 
peritonitis, is only a remote consequence of the injury and 
second where the complication which is the intervening cause 
of death is itself a practically inevitable sequence to the injury: 
Held: Broadly speaking, the courts would have to undertake the 
exercise to distinguish between two types of cases; first, where 
the intervening cause of death, like peritonitis, is only a remote 
and a rather improbable consequence of the injury; then it can be 
said that the injury is one which may, in particular circumstances, 
result in death, but which may not in ordinary course of nature 
be likely to lead to it – Secondly, where the complication which 
is the intervening cause of death is itself a practically inevitable 
214
[2025] 10 S.C.R.
Supreme Court Reports
sequence to the injury – In that event, the probability is very high 
indeed, amounting to practical certainty i.e., death is a result in 
due course of natural events – A deep abdominal thrust with a 
knife followed by injury to the internal organs is practically certain 
to result in acute peritonitis causing death – It is clearly a case of 
murder u/s.302 and not merely of culpable homicide. [Para 66(f)]
Penal Code, 1860 – s.300 – The Courts are to always look into 
the natu

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