Maniklal Sahu v. State of Chhattisgarh, 2025

The appellant was convicted under Section 307 IPC for attempting to murder the victim by inflicting multiple injuries.

During appeal, the key argument raised was that none of the individual injuries alone were fatal in the ordinary course of nature to cause death.

However, the prosecution contended that the cumulative effect of the injuries inflicted was sufficient to cause death, and hence the conviction was valid.

The Supreme Court dismissed the appeal and affirmed the conviction under Section 307 IPC.

The Court held that the cumulative injuries inflicted by the appellant were sufficient in the ordinary course of nature to cause death, even if no single injury alone would have resulted in death.

If it is proved that the injury was fatal and intended to cause death, then even if death occurred later due to complications like septicaemia, it amounts to murder under Section 300 IPC.

Injuries that are sufficient in the ordinary course of nature to cause death, when inflicted intentionally, attract liability under Section 302 IPC even if death occurs after some time due to complications.

Injuries that are imminently dangerous to life and lead to death via complications (like septicaemia), also fall under Section 302 IPC, provided the accused had the necessary knowledge or intent.

The possibility that medical treatment could have prevented death is irrelevant when determining if injuries were sufficient in the ordinary course to cause death.

If the complications (like infection or organ failure) naturally flow from the original injury, the person causing the injury is still held responsible for causing death.

The Courts must distinguish between: Cases where the complication (like peritonitis) is remote or unlikely — the injury may not be considered likely to cause death. Cases where the complication is an inevitable or natural result of the injury — death is deemed a natural consequence and the case qualifies as murder.

Even if no individual injury was fatal, multiple injuries taken together can cumulatively be sufficient to cause death in the ordinary course of nature.

The Courts must assess whether the injuries were likely to cause death or such bodily injuries as the accused knew could result in death, regardless of later complications or intervening causes.

What matters is whether death was a probable outcome in the natural course, not whether it occurred from a rare or unexpected complication.

If the original injury is fatal in nature, and complications like infection naturally result from it, then the injury is treated as the proximate cause of death and liability for murder arises.

The Court reiterated well-established principles regarding causation in criminal law when evaluating attempt to murder, courts must not focus only on individual injuries but also consider the combined effect.

If the natural and probable consequences of the act are death or grievous injury, then Section 307 IPC is rightly attracted.

The decision strengthens the jurisprudence around criminal intention and knowledge, especially when death is avoided by chance or medical intervention.

The ruling aligns with precedent, particularly decisions that emphasize the "proximate cause" test rather than requiring a direct and fatal injury.