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citation codes
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  • Art. 134 (1) (c) of the Constitution. 3. Section 396, Indian Penal Code
  • SECTION 342 CRIMINAL PROCEDURE CODE
  • section 395, Indian Penal Code. 15.
  • section 390, Indian Penal Code
  • section 395, Indian Penal Code
  • section 396, Indian Penal Code,
  • section 302, Indian Penal Code,
  • section 391, Indian Penal Code
  • section 391, Indian Penal
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Cites
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Citation Codes
Equivalent Citations
citation codes
Case Number
Advocates
Judges
Acts
  • Art. 134 (1) (c) of the Constitution. 3. Section 396, Indian Penal Code
  • SECTION 342 CRIMINAL PROCEDURE CODE
  • section 395, Indian Penal Code. 15.
  • section 390, Indian Penal Code
  • section 395, Indian Penal Code
  • section 396, Indian Penal Code,
  • section 302, Indian Penal Code,
  • section 391, Indian Penal Code
  • section 391, Indian Penal
Smart Summary

Factual and Procedural Background

The appellant, together with several accomplices, entered the house of one Mendai in the early hours of 10/11 September 1954 with the intention of committing robbery. Their effort was thwarted when the occupants raised an alarm that attracted nearby villagers. The dacoits fled empty-handed, pursued by Mendai and Ganga. While crossing the ditch of Pipra Farm, the appellant fired a pistol shot to free a companion who had been apprehended, fatally wounding Mendai.

The Sessions Judge convicted the appellant under Section 396 of the Indian Penal Code (IPC) and sentenced him to death. The Allahabad High Court affirmed both conviction and sentence, rejecting a legal argument that Section 396 could not apply because the gang escaped without booty. The High Court nevertheless certified the case for appeal to the Supreme Court under Article 134(1)(c) of the Constitution. The present opinion disposes of that appeal.

Legal Issues Presented

  1. Whether a murder committed by one member of a dacoity gang while retreating without any stolen property is a murder committed “in so committing dacoity” for the purposes of Section 396 IPC.
  2. Whether, if Section 396 is inapplicable, the appellant can still be convicted of murder under Section 302 IPC on the basis of the same evidence and charge framing.

Arguments of the Parties

Appellant’s Arguments

  • The transaction of dacoity ended when the gang fled empty-handed; any subsequent homicide was a separate act not covered by Section 396.
  • At most, the facts establish an offence under Section 395 IPC (dacoity without murder), not dacoity with murder.

Prosecution’s Arguments

  • The dacoity continued until the dacoits achieved a safe retreat; the murder committed to secure that retreat was therefore part of the same transaction and falls within Section 396.
  • Even if the court were to disagree on Section 396, the evidence squarely establishes individual liability for murder under Section 302 IPC.
  • Reliance was placed on several High Court decisions treating killings during flight from a dacoity as murders committed “in so committing” the dacoity.

Table of Precedents Cited

Precedent Rule or Principle Cited For Application by the Court
Emperor v. Chandar, 1906 All WN 47 ; 3 Cr LJ 294 A murder committed after the dacoits had abandoned the robbery was held not to be “in committing dacoity”; conviction reduced from §396 to §395. Cited by the appellant; the Court acknowledged its support for the defence position but ultimately distinguished the present case by convicting under §302.
Sirajuddin v. State, AIR 1951 All 834 Whether the murder is part of the dacoity is a question of fact and degree dependent on the circumstances.
Kaley v. State, AIR 1955 All 420 Reaffirmed that retreat with booty may keep the transaction alive; observed Chandar laid the law “too widely.” Referenced to show the spectrum of High Court views; not determinative of the present appeal.
Monoranjan Bhattacharjya v. Emperor, AIR 1932 Cal 818 (FB) Test of whether the dacoity transaction had concluded before the murder occurred. Cited to illustrate that separation of transactions removes the case from §396.
Queen-Empress v. Sakharam Khandu, 2 Bom LR 325 If the retreat is closely connected in time and space with the robbery, it remains part of the common object. Used to demonstrate that the issue is fact-specific, depending on continuity of the criminal enterprise.
Willie (William) Staney v. State of Madhya Pradesh, AIR 1956 SC 116 An accused may be convicted of a graver offence (e.g., §302) if the charge and evidence have focused his attention on that act, even when originally charged under another section. Relied upon to justify convicting the appellant under §302 IPC without a separate murder charge.

Court's Reasoning and Analysis

The Court began by examining the statutory scheme. Section 391 IPC defines dacoity to include an “attempt to commit robbery” by five or more persons, while Section 396 punishes murder committed “in so committing” the dacoity. Because the gang never obtained property, the event amounted only to an attempt to commit robbery, a fact that nonetheless completes the offence of dacoity under Section 395.

The appellant urged that the dacoity transaction ended once the assailants fled without loot, making the subsequent shooting a separate occurrence outside Section 396. The Court acknowledged “considerable force” in this contention, noting that earlier authority (Emperor v. Chandar) supported it.

However, the Bench deemed it unnecessary to give a definitive ruling on that legal question. The charge under Section 396 had already informed the appellant that he was being tried for both the dacoity and the specific murder of Mendai. The evidence, accepted concurrently by the trial court and the High Court, unequivocally identified the appellant as the shooter. His examination under Section 342 CrPC also addressed that allegation. Relying on Willie Staney, the Court held that, in these circumstances, the appellant could be convicted under Section 302 IPC without prejudice, even if Section 396 were inapplicable.

Holding and Implications

Appeal Dismissed; Conviction and Sentence of Death Confirmed.

The Court confirmed the findings of guilt and the sentence originally imposed, expressly convicting the appellant of murder under Section 302 IPC. While it refrained from a conclusive interpretation of the scope of Section 396 in “retreat without booty” scenarios, the decision underscores that an appellate court may sustain a capital conviction under Section 302 when the charge under Section 396 necessarily includes and highlights the act of murder, thereby causing no prejudice to the accused. No new precedent on the reach of Section 396 was established.

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    Shyam Behari v. State Of U.P

    : The appellant had been charged inter alia with having committed an offence under section 396, Indian Penal Code in that he on 10/11th day of September, 1954, about two or three gharis before sunrise in village Banni Purwa, hamlet of Banni, police station Kotwali, Kheri, along with other persons committed dacoity in the house of Mendai and that in the commission of such dacoity, murder was committed by one of the members. The learned Sessions Judge found that the appellant, and the others, had entered the house of Mendai with intent to commit a robbery but were foiled in the attempt owing to Mendai and Ganga having raised a hue and cry. The residents of Banni Purwa and the adjoining 'abadi' of village Banni arrived on the scene and the appellant and his companions, without collecting any booty, ran away from the house of Mendai. They were chased by Mendai and Ganga and when they were crossing the ditch of Pipra Farm, Mendai caught hold of one dacoit. Another dacoit who was identified by several witnesses as the appellant thereupon fired a pistol shot which hit Mendai and Mendai fell to the ground and was removed to the hospital where he died. The further movement of the appellant thereafter need not be recounted here. The learned Sessions Judge as also the High Court recorded concurrent findings of fact that the appellant shot and killed Mendai to secure the release of one of his companions and also to ensure their safe retreat.

    2. These concurrent findings of fact ware enough to dispose of the appeal of the appellant before the High Court. He, however, raised a question of law, viz., that he may be guilty under section 395 but not under section 396, Indian Penal Code because any murder committed by the dacoits during their fight when they were running away without any booty could not be treated as murder committed in the commission of the dacoity. A distinction was sought to be drawn between a case where the dacoits were escaping with the booty and the case where the dacoits were running away without any booty. It was argued that it would be an offence of dacoity with murder when the dacoits, after committing robbery, were running away with the booty and in order to escape with the booty they committed the murder and that it would not be a dacoity with murder when dacoits had no. booty with them but in order to avoid being caught they committed the murder. The High Court negatived this contention and held that section 396, Indian Penal Code would be attracted even where an attempt had been made to commit dacoity and a murder was committed when the dacoits were trying to make a safe retreat. The conviction of the appellant under section 396, Indian Penal Code was therefore confirmed along with the sentence of death passed upon him by the learned Sessions Judge. On an application made by the appellant for Leave to Appeal to this Court, the High Court granted to him the necessary certificate under Art. 134 (1) (c) of the Constitution.

    3. section 396, Indian Penal Code provides that

    if any one of five of more persons, who are conjointly committing dacoity, commits murder in so committing dacoity, every one of those persons shall be punished with death, or imprisonment for life, or rigorous imprisonment for a term which may extend to ten years, and shall also be liable to fine
    .

    Dacoity is defined in section 391, Indian Penal as under : -

    When five or more persons conjointly commit or attempt to commit a robbery, or where the whole number of persons conjointly committing or attempting to commit a robbery, and persons present and aiding such commission or attempt, amount to five or more every person so committing, attempting or aiding, is said to commit dacoity

    .

    4. The essential ingredients of the offence of dacoity, therefore, are that five or more persons should be concerned in the commission of the offence and they should either commit or attempt to commit a robbery.

    5. There was, in the circumstances of the present case an attempt to commit robbery by the appellant and his companions though in fact no. robbery was committed by reason of the. hue and cry raised by Mendai and Ganga. The dacoits took to their heels without collecting any booty when they found that the villagers from Banni Purwa and Banni came immediately to the aid of Mendai and Ganga. The offence of dacoity was, therefore, completed the moment they took to their heels without any booty. There was an attempt to commit a robbery though it was foiled as stated above; nonetheless the dacoits would have been guilty and could have been punished for the offence under section 395, Indian Penal Code which prescribes the punishment for dacoity.

    6. The prosecution, however, contended that the appellant was guilty not only of the offence under section 395 Indian Penal Code but also under section 396, Indian Penal Code because, the appellant and his companions were conjointly committing the dacoity and the appellant who was the one of the members committed the murder of Mendai in so committing the dacoity. If the transaction which commenced with the entry of the appellant and his companions in the house of Mendai continued right up to the time that the appellant shot at Mendai while crossing the ditch of the Pipra Farm the murder of Mendai committed by the appellant could certainly be said to have been committed by the appellant in so committing the dacoity. It was, however, contended on behalf of the appellant that the transaction of dacoity was completed the moment the dacoits took to their heels without any booty and the murder of Mendai committed by the appellant, was another transaction which was dissociated from that transaction of dacoity. The murder of Mendai accordingly was committed by the appellant not in committing the dacoity but independently of the transaction of dacoity when the dacoits were running away for safety and had proceeded a considerable distance from the house of Mendai where the dacoity had been committed.

    7. On a plain reading of section 391, Indian Penal Code it would appear that in order that a dacoity can be said to have been committed it is necessary that five or more persons conjointly commit a robbery or attempt to commit a robbery. If a robbery was committed, the dacoits would have the booty with them but if the matter rested only with an attempt to commit a robbery there would be no. question of the dacoits having any booty with them. It is necessary in this context to note the definition of robbery given in section 390, Indian Penal Code and it is laid down there that

    theft is 'robbery' if, in order to the committing the theft, or in committing the theft, or in carrying away or attempting to cam away property obtained by theft, the offender, for that end, voluntarily causes or attempts to cause to any person death or hurt or wrongly restrain, or fear of instant death or of instant hurt, or of instant wrongful restraints.

    There, was in the circumstances of the present case a clear attempt at robbery but it did not comprise the carrying away or attempting to carry away property obtained by theft. No. theft was committed nor were the dacoits engaged in carrying away the property obtained by theft so that the transaction of dacoity stopped short at the mere attempt to commit robbery. If the transaction of dacoity was to extend up to the ditch of the Pipra Farm there should have been the carrying away or an attempt to carry away the property obtained by theft, which could not there unless and until the booty had been collected by the dacoits at the house of Mendai and they were running away for safety along with booty. If the appellant had shot at Mendai while he and his companions were thus the unning away with the booty the murder of Mendai could certainly be said to have been committed in the commission of the dacoity.

    8. The prosecution, however, relied upon the decision of the Allahabad High Court in Sirajuddin v. state, 1951 AIR(All) 834 (A) and Kaley V. The State, (S) 1955 AIR(All) 420 (B) as also the decisions of the Calcutta High Court in Monoranjan Bhattacharjya V. Emperor, 1932 AIR(Cal) 818 (FB) (C) & the Bombay High Court in Queen-Empress v. Sakharam Khandu, 2 Bom LR 325 (D) in support of its contention that even though the dacoits were running away without collective any booty and one of them committed murder in order to ensure their safe retreat that murder could be said to have been committed in committing the dacoity. The appellant, on the other hand, relied upon the decision of the Allahabad High Court in Emperor V. Chandar, 1906 All(WN) 47 : 3 CrLJ 294 (E).

    9. The case of Emperor v. Chandar (E) no. doubt lends support to the contention of the appellant. The dacoits in that cast were not carrying off any property. Yet the offence of dacoity is defined in section 395, Indian Penal Code was held to have been completed by them, an attempt to commit robery by the gang being clearly proved. It was, however, found that the attempt to commit robbery was frustrated by arrival of the villagers and at the time when the deceased was killed the dacoits were bent upon escaping from the village and had abandoned their intention to rob. The Court was therefore of the opinion that, in the facts of the case before it, it could not be held that there had been murder "in so committing the dacoity and the conviction under section 396 could not be sustained."

    The conviction under section 396, Indian Penal Code, was accordingly set aside and the findings was altered to one under section 395, Indian Penal Code. In so far, however, there was evidence on record which, if proved, would justify a charge against the appellant of an offence under section 302, Indian Penal Code, for which offence he had not yet been tried, the Court thought it just and proper that he should be tried for that offence and a direction was accordingly given that the appellant be committed to the court of the Magistrate having jurisdiction, to stand trial at the court of sessions on the charge of murder.

    10. In 1951 AIR(All) 834 (A) also, the dacoits were running away without collecting any booty by reason of the villagers having put up a bold front. The court there held that the question whether murder was committed by the dacoit while committing dacoity was a pure question of fact and of degree, not to be determined by any general rule, but by the special circumstance of each case. On the facts and circumstances of the case the Court, however, came to the conclusion that there was nothing to show that the murder was so dissociated by time or space from the dacoity that it could be held that one chapter had closed and a now chapter had begun. The Court having held that the transaction of dacoity was continuing right up to the moment when the murder was committed, the case fell within section 396, Indian Penal Code. This decision thus turned on the facts of the case and could not be relied upon as laying down any general proposition that even though the dacoits were running away without collecting any booty they could be charged with having committed the murder in the commission of the dacoity.

    11. (S) 1955 AIR(All) 420 (B) was a case where the dacoits were running away with the booty. The only importances of that decision is that the case of 1906 All(WN) 47 : 3 CrLJ 294 (E) was considered by the learned Judges there and they pointed out that the law in that case appeared to have been laid down rather "too widely."

    12. (S) 1932 AIR(Cal) 818 (FB) (C) also laid down the test whether the transaction of dacoity was complete and another transaction and a separate one had begun. If it could be predicated on the fact of a particular case that the murder was committed after the transaction of dacoity was complete and another and a separate transaction had begun, such murder would not fall within the purview of section 396, Indian Penal Code. Even though in that case there were indications to show that the dacoits had abandoned the booty before the murder was committed, the ratio decidendi of the case was, as noted above, the demarcation which was made between the completion of the transaction of dacoity on the one hand and beginning of another and a separate transaction in the case of which latter transaction only the murder was committed.

    13. 2 Bom LR 325 (D) turned on the question whether the retreat was so separated by time or space from the offence which was the common object of the assembly as not to form part of it. That was held to be a pure question of fact and of degree not to be determined by any general rule but by the special circumstances of each case. On the facts and circumstances of that case, the Court held that there was no. such separation, that the retreat was an essential part of the common criminal purpose and that it was the continuation of the actual dacoity while the dacoits were still acting in concert, and was so closely and necessarily connected with the actual demand of 'khand' that it must be taken that the murder was committed in prosecution of the common object of the assembly.

    14. There is, therefore, considerable force in the contention urged on behalf of the appellant before us that, In the facts and circumstances of the present case, the transaction of dacoity had ended the moment the dacoits took to their heels and another and a separate transaction took place when the appellant shot at Mendai while crossing the ditch of the Pipra Farm and that, therefore, the appellant could not be convicted of having committed the offence under section 396, Indian Penal Code. Learned counsel for the appellant strenuously contented that the conviction of the appellant under section 396, Indian Penal Code should be quashed and that on the concurrent findings of fact recorded by both the Courts below the conviction should be altered to one under section 395, Indian Penal Code.

    15. It is, however, unnecessary to do so because in the facts and circumstances of the present case the appellant is liable to be convicted of the offence under section 302, Indian Penal Code without anything more. The charge under section 396, Indian Penal Code comprised of two ingredients : - (1) The commission of the dacoity, and (2) the commission of the murder in so committing the dacoity. The first ingredient was proved without any doubt and was not challenged by the learned counsel for the appellant, The second ingredient also was proved in any event as regards the, commission of the murder because the attention of the accused was focussed not only on the commission of the offence while committing the dacoity but also on the individual part which he took in the commission of that murder. So far as he was concerned, he knew from the charge which was framed against him that he was sought to be made responsible not only for the commission of the dacoity but also for the commission of the murder in committing such dacoity. The evidence which was led on behalf of the prosecution specifically implicated him and he was named by the prosecution witness as the person who shot at Mendai while crossing the ditch of Pipra Farm. His examination under section 342 of the Criminal Procedure Code also brought out that point specifically against him and he was questioned in that behalf. Both the courts below recorded their concurrent findings of fact in regard to the part taken by the appellant in the commission of the murder of Mendai. Under these circumstances it could not be urged that the appellant could not be convicted of the offence under section 302, Indian Penal Code if such a charge could be made out against him (Vide our decision in Willie (William) Staney V. State of Madhya Pradesh, Cri App No. 6 of 1955 D/- 31-10-1955 : ( (S) 1956 AIR(SC) 116 ) (F).

    16. We do not, therefore, think it necessary to express any definite opinion on the question of law mooted in the order of the High Court granting to the appellant certificate of fitness for appeal. Suffice it to say that even if the conviction of the appellant under section 396, Indian Penal Code be not perchance sustainable, the murder of Mendai having been committed after the dacoits had taken to their heels without collecting any booty, the case against the appellant in regard to the commission of the murder of Mendai has been proved beyond any shadow of doubt and under those circumstances we would convict the appellant of having committed the offence under section 302, Indian Penal Code.

    17. We accordingly see no. force in this appeal and dismiss the same. The conviction of the appellant will stand confirmed and also the sentence of death passed by the learned Sessions Judge upon him.

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    Shyam Behari v. State Of U.P
    (Oct 5, 1956)