Roshan Lal v. State of Haryana
Supreme Court of India2026 INSC 524Bench: Justice Sanjay Karol and Justice N. Kotiswar Singh
The Supreme Court reiterated the well-settled but frequently misapplied principle that the gravity or seriousness of the injuries inflicted on the victim cannot, by itself, sustain a conviction under Section 307 of the Indian Penal Code, 1860 for attempt to murder. Section 307 is essentially a 'mens rea' offence, and what the prosecution must establish, by direct or circumstantial evidence, is that the accused did the act in question with the specific intention or with such knowledge as is necessary to constitute the offence of murder under Section 300 IPC, in circumstances where, had death actually ensued, the act would have amounted to murder. The Bench emphasised that the inquiry must focus on the totality of circumstances — the nature of the weapon used, the part of the body targeted, the force employed, the number of blows, the surrounding facts and any prior animosity or motive — and not merely on the medical opinion that the injury was 'dangerous to life'. The mere fact that an injury is medically classified as dangerous, or that the victim narrowly escaped death, does not by itself convert an offence of voluntary causing of grievous hurt under Sections 325 or 326 IPC into an attempt to murder under Section 307 IPC. Applying these principles to the case, where the accused had assaulted the informant with lathis causing head injuries declared dangerous to life, the Court found that the requisite intention or knowledge to kill had not been independently established by the prosecution and that the offence properly disclosed was one of voluntary causing of grievous hurt. The conviction under Section 307 was accordingly modified.