In a case where the Delhi High Court rejected a petition contesting the accusation of murder against a Station House Officer (SHO) related to a man's death, the court determined that a panel of seven reputable doctors, based on their medical opinion, found that the nature of the injury in question had the potential to cause death under normal circumstances.

Therefore, the High Court concluded that there was no issue with framing a charge under Section 302 of the Indian Penal Code (IPC) against the petitioner. Justice Jasmeet Singh, presiding as a Single Judge, remarked that it is entirely possible for a person to die as a result of a single blow. There is no requirement that the offense under Section 302 IPC must involve the infliction of multiple blows or extensive bodily harm on an individual.

In the current case, the Bench also emphasized that the injury in question was inflicted on the deceased's head, which is a sensitive and critical part of the body. Therefore, any forceful impact or injury to the head has the potential to result in the death of an individual. The determination of whether the blow was adequate to cause death in the ordinary course of nature and whether the petitioner was aware of this can only be established during the course of the trial.

As per the facts in this case, an FIR was registered against SHO Jagat Narayan Singh (the revisionist), as well as SI Akshaya Mishra, SI Vijay Mishra, and three other police officials. The FIR was initiated based on a complaint filed by Smt. Meenakshi Gupta, the wife of the deceased, Manish Gupta. The allegations in this case revolved around Manish Gupta and two others checking into Hotel Krishna Palace in Gorakhpur. During the night, SHO Jagat Narayan Singh and the other accused police officers arrived at the hotel. They made inquiries with the hotel manager and were informed that room No. 512 was occupied by three individuals from different districts of Uttar Pradesh and Haryana.

In response to these events, the police officers decided to inspect the room in question. Upon entering the room, SHO Jagat Narayan Singh (the revisionist) requested the occupants to provide their identification cards and explain the purpose of their visit to Gorakhpur. Subsequently, he also asked the occupants to accompany them to the police station for further inquiry. It was during this process that a dispute arose when the deceased, Manish Gupta, protested against being taken out of the room. It was alleged that in the course of this disagreement, the revisionist pushed Manish Gupta's forehead against a wall. This action caused Manish Gupta to lose consciousness and fall to the floor. Following this incident, the revisionist, along with other police officials, transported the unconscious man to the hospital, where he was declared deceased. As a result, the Trial Court proceeded to frame charges against the revisionist under various sections of the Indian Penal Code (IPC), including Section 302 (murder), Section 323 (voluntarily causing hurt), Section 325 (causing grievous hurt), Section 201 (causing disappearance of evidence), Section 218 (public servant framing incorrect record), Section 149 (common intention), Section 34 (acts done by several persons in furtherance of common intention), and Section 120B (criminal conspiracy).

Upon reviewing the submissions, the Bench determined that the statement given by the hotel manager was straightforward and left no room for ambiguity. The hotel manager had clearly stated that it was the revisionist who had assaulted the deceased, leading to his fall. The Bench stressed that, at this point in the proceedings, the statements provided by the hotel manager were adequate grounds to justify the framing of charges against the revisionist.

The Bench also noted that the injury inflicted on the deceased was to his head, which is a sensitive and vital part of the body. Consequently, any forceful impact or injury to the head had the potential to result in an individual's death.

The Bench underscored that the question of whether the blow delivered was adequate to cause death in the ordinary course of nature, and whether the revisionist was aware of this fact, could only be established through a proper trial. At this initial stage, such arguments were insufficient to justify avoiding the framing of charges under Section 302.

The Bench highlighted several key factors in its decision: firstly, a bodily injury was inflicted; secondly, the injury was not unintentional or accidental, as it was a result of a conscious assault by the revisionist; and thirdly, the nature of the injury was serious, particularly because it occurred on a vital part of the body, namely the head.

Additionally, the High Court took note of the fact that the injury had the potential to cause death in ordinary circumstances. Based on this observation, the court concluded that the fundamental elements of Section 300 of the Indian Penal Code (IPC) seemed to be prima facie met in the current case.

Hence, the High Court ruled that the Special Judge had accurately understood the relevant facts and the applicable legal principles. The court also found that the Special Judge had appropriately assessed and considered the evidence presented before him. Consequently, the High Court rejected the petition.

Case: Jagat Narayan v. Central Bureau of Investigation, CRL.REV.P. 212/2023.