SC Upholds Conviction Under Common Intention: Severity of Injuries Alone Cannot Reduce Punishment

The Supreme Court recently held that individuals acting with a common intention cannot escape harsher punishment merely because their inflicted injuries were less severe than those caused by co-accused. A bench comprising Justice Sudhanshu Dhulia and Justice Prashant Kumar Mishra overturned the Karnataka High Court's decision to downgrade the conviction of an accused from Section 326 IPC (voluntarily causing grievous hurt by dangerous weapons) to Section 324 IPC (voluntarily causing hurt by dangerous weapons).

Key Observations of the Court

• The case involved Accused No. 2, who used a chopper to assault two individuals along with Accused No. 3, who used a knife.
• The Court observed that merely because the injuries inflicted by Accused No. 2 were less severe than those caused by Accused No. 3, the conviction under Section 326 IPC could not be reduced to Section 324 IPC.
• "Both accused were accomplices, and their actions were driven by common intention under Section 34 IPC," the Court noted.

Rejection of Defense Arguments

• The defense argued that the accused had no intention to cause grievous harm and that their actions were spontaneous.
• The Court rejected this, emphasizing that common intention and meeting of minds can arise during the incident itself, negating the need for prior planning.

Court's Reasoning

• The presence of both accused at the crime scene with deadly weapons was sufficient to establish their shared intent.
• The Court noted, "Even if the injuries were not grievous or inflicted only on the hand, the actions clearly indicated the common intention to harm the victims."

Case Decision

• The Supreme Court allowed the State of Karnataka's appeal, reinstating the conviction of Accused No. 2 under Section 326 IPC read with Section 34 IPC.
• The Court sentenced Accused No. 2 to two years of rigorous imprisonment (RI) and a fine of ₹75,000, matching the sentence imposed on Accused No. 3.
• The accused was directed to surrender within four weeks to serve the remaining sentence.

Significance of the Judgment

• The ruling underscores the importance of common intention in criminal cases, reaffirming that the severity of injuries alone cannot determine the quantum of punishment.
• It highlights the judiciary's commitment to ensuring accountability for collective criminal actions.

Case Title: U. SUDHEERA & OTHERS VERSUS C. YASHODA & OTHERS

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