3.1 Precedents Cited

The judgment references several crucial precedents to delineate the boundaries of individual criminal liability within a group offense:

• Camilo Vaz v. State Of Goa (2000) 9 SCC 1: This case established the criteria for convicting an individual under Section 304 Part II IPC, emphasizing the need for the accused to possess knowledge that their act is likely to cause death, even in the absence of intent to kill.
• Bawa Singh v. State Of Punjab (1993 Supp (2) SCC 754: Addressed the necessity of medical evidence to establish whether injuries are sufficient to cause death, impacting decisions to reduce charges from murder to culpable homicide.
• Sarup Singh v. State Of Haryana (2009) 16 SCC 479: Highlighted that a single lethal blow can be sufficient for a murder conviction, depending on the nature and location of the injury.
• Ghana Pradhan & Ors. v. State of Orissa (1991 Supp (2) SCC 451: Focused on the requirement of a common intention among accused individuals to sustain a joint liability for the offense.

These precedents collectively aid in shaping the Court's approach to assessing individual responsibility within collective criminal actions, ensuring that convictions are proportionate to each individual's intent and participation.

3.2 Legal Reasoning

The Supreme Court's primary legal reasoning centered on the principle of common intention under Section 34 IPC. Section 34 mandates that when a criminal act is done by several persons in furtherance of a common intention, each person is liable for the act in the same manner as if it were done by him alone.

For A-1, A-2, and A-4, the evidence unequivocally demonstrated their active participation with a shared intent to murder, justifying their conviction under Section 302 read with Section 34 IPC. Their roles in wielding lethal weapons and inflicting fatal injuries established a collective intent to cause death.

Conversely, A-3's involvement, while contributory, lacked demonstrable common intent. The court observed that A-3 only used a stone for assaulting the deceased and did not participate in the exchange of lethal blows with weapons like the axe or sword. The post-mortem report indicated that the fatal injury was consistent with the weapon used by A-1 and A-2, not the stone wielded by A-3.

Consequently, the Court concluded that A-3 did not share the common intention requisite for a Section 302 conviction. However, recognizing his active role in the assault and the knowledge that his actions could likely result in death, A-3 was held liable under Section 304 Part II IPC, which deals with culpable homicide not amounting to murder.

3.3 Impact

This judgment has several significant implications for future criminal cases:

• Clarification on Common Intention: The decision provides a nuanced understanding of how individual intent and participation are assessed within collective offenses, ensuring that only those with demonstrable intent are subjected to the gravest penalties.
• Application of Section 304 Part II IPC: By differentiating between intent and knowledge, the Court reinforces the appropriate application of Section 304 Part II, ensuring that only those whose actions foreseeably lead to death, without explicit intent, are convicted under this provision.
• Evidence-Based Convictions: Emphasizes the necessity for concrete evidence linking each accused to the intent and actions constituting murder, discouraging blanket convictions based solely on association or presence at the crime scene.
• Forensic Corroboration: Highlights the importance of forensic evidence in establishing the specific contributions of each accused, thereby fostering meticulousness in trials involving multiple perpetrators.

Overall, the judgment promotes a fairer judicial process by ensuring that convictions and sentences are tailored to the individual's actual culpability, thereby upholding the principles of justice and proportionality.