ABC Live Editor Note:

At ABC Live, we believe judgments of the Supreme Court should not be read only as legal outcomes but as instruments shaping justice delivery in India. The case of Maniklal Sahu v. State of Chhattisgarh is a telling example. While mainstream reporting often reduces such cases to headlines on conviction or acquittal, our editorial team goes deeper.

This analysis explains why the doctrine of causation matters and how the Court’s ruling prevents lower courts from blurring the line between murder and attempt to murder when deaths occur after medical complications. We also highlight weaknesses in judicial writing, where verbosity sometimes dilutes the clarity of legal principles.

We are publishing this report now because Section 302 vs. Section 307 IPC continues to confuse trial courts, often leading to inconsistent justice. By unpacking the Supreme Court’s reasoning, ABC Live seeks to provide lawyers, students, and citizens with a clear understanding of how the law of causation is evolving.

Our commitment remains the same: research-driven, evidence-based, and globally contextual reporting on law and policy.

— ABC Live Editorial Team

New Delhi (ABC Live): The Supreme Court’s decision in Maniklal Sahu v. State of Chhattisgarh [2025 INSC 1107] is a turning point in the law of causation in homicide cases. It deals with a common legal dilemma: when a victim survives for months after an assault but later dies due to complications, should the accused face punishment for murder under Section 302 IPC or for attempt to murder under Section 307 IPC?

In Maniklal Sahu v. State of Chhattisgarh, the deceased lived for nine months after suffering a spinal injury. That injury later caused septicemia, pneumonia, and eventual death. The High Court converted the conviction to Section 307 IPC, claiming the death was due to medical complications and lack of proper treatment. The Supreme Court, however, ruled that this approach was flawed.

1. Case Overview

• Background: In Maniklal Sahu v. State of Chhattisgarh, the appellant was convicted for causing the death of Rekhchand Verma. The High Court reduced the conviction from Section 302 IPC (murder) to Section 307 IPC (attempt to murder), reasoning that death occurred due to later complications.

• Supreme Court’s Role: To decide whether the High Court erred in treating the death as too remote and whether the causal chain was intact.

2. Core Legal Issues

1. Doctrine of Causation in Homicide

   • Could septicemia and pneumonia be legally traced back to the original injury in Maniklal Sahu v. State of Chhattisgarh?

   • Does Explanation 2 to Section 299 IPC apply, which fixes liability even if proper treatment might have prevented death?

2. Distinction Between Section 302 and Section 307 IPC

   • Section 302 applies if the injuries are sufficient in the ordinary course of nature to cause death.

   • Section 307 applies only if there is an attempt to kill but the victim survives.

3. Strengths of the Judgment

• Strong Medical-Legal Analysis: The Court relied on doctors’ testimonies, which showed that the death in Maniklal Sahu v. State of Chhattisgarh was a direct result of the spinal injury leading to systemic infection.

• Doctrinal Clarity: It carefully explained the difference between proximate and remote causation, using both Indian and English precedents.

• Corrective Role: The judgment corrected the High Court’s mistake and reaffirmed that delay in death does not reduce liability for murder.

• Educational Structure: Clear headings and case references make it a teaching tool for students and a guide for lower courts.

4. Weaknesses of the Judgment

• Excessive Length: At 42 pages, the judgment repeats principles on causation several times.

• Old Precedents Overused: Heavy reliance on 19th and early 20th-century English cases could have been shortened.

• Limited Policy Context: The Court did not fully discuss the role of poor healthcare in complicating such cases.

• Blurred Ratio: The judgment could have delivered a clearer test for when Section 302 must apply instead of Section 307.

5. Improvements Suggested

• Sharper Ratio Decidendi: A one-line test would help: “If injuries are sufficient in the ordinary course of nature to cause death, Section 302 applies even when death is delayed by complications.”

• Concise: Shorter case surveys would make the reasoning more direct.

• Plain Language: Replace Latin and technical jargon with plain English.

• Brief Summary at the Start: A short “Held” paragraph would make the outcome immediately clear.

6. Judgment Rating

• Doctrinal Correctness: ????? (5/5)

• Clarity & Structure: ????? (4/5)

• Quality of Writing: ????? (4/5)

• Overall Impact: ????? (4.5/5)

(Could reach ????? with the suggested improvements.)

7. Conclusion

The Supreme Court in Maniklal Sahu v. State of Chhattisgarh reaffirmed a key principle: medical complications and delayed death do not break the chain of causation if they naturally flow from the injury. The judgment is long but doctrinally sound. It offers valuable precedent for future homicide trials and strengthens clarity between Section 302 and Section 307 IPC.

? Resources (Copy-Pastable Links)

1. Supreme Court of India – Official Website (Judgment repository):
   https://www.sci.gov.in
2. Indian Kanoon – Full Judgment Text (check by citation or party name):
   https://indiankanoon.org
3. SCC Online – Case Law Database (subscription required):
   https://www.scconline.com
4. Casemine – AI-linked case law search:
   https://www.casemine.com
5. Textbook Reference – Modi’s Medical Jurisprudence & Toxicology (classic source cited by SC):
   https://archive.org/details/modis-medical-jurisprudence

Read Complete Judgment click Here