Roshan Lal v. State of Haryana and Anr. 2026 INSC 524

On the night of June 5, 2000, the informant, Amar Singh (PW3), was performing his duties as a night watchman in his village. He came across a group of people assaulting an individual near the house of Rama Nand (PW4). When Amar Singh intervened, the accused persons turned on him in furtherance of their common intention.

Sajjan Singh struck the complainant’s head with a lathi; Satya Parkash hit the complainant’s right hand with a lathi; Roshan Lal also delivered a lathi blow to the complainant’s head; and Dharamvir (who was later acquitted) assaulted him with fists and kicks.

Amar Singh sustained a compound fracture of the scalp and a parietal haematoma, and he eventually faced life-threatening complications, including multi-organ failure and deranged kidney and liver functions. The Trial Court convicted Roshan Lal, Satya Prakash, and Sajjan Singh under Section 307 (Attempt to Murder) read with Section 34 and Section 506 of the IPC, sentencing them to seven years of rigorous imprisonment. The High Court of Punjab & Haryana subsequently upheld this conviction.

Elements of Section 307: To sustain a conviction, the prosecution must establish both mens rea (intention or knowledge to commit murder) and actus reus (the actual act). Intention is inferred from surrounding circumstances, such as the weapon used, the body parts targeted, and the motive. In this case, the Court found no prior history of enmity or evidence of pre-conceived planning to kill the informant.

Spontaneity of the Act: The incident occurred suddenly when the informant intervened in an existing altercation. The assault was a spontaneous reaction in the heat of the moment rather than an attempt to eliminate him.

Nature of Weapons: The appellants used ordinary lathis, which the Court did not consider “inherently deadly weapons” in this specific factual context. The Court concluded the primary goal was likely to deter or intimidate the informant.

Grievous Hurt vs. Attempt to Murder: While the injuries were “dangerous to life,” the Court held that gravity alone does not prove an intention to murder under Section 307 IPC. However, the injuries (fractures) clearly fell under the definition of “Grievous Hurt” under Section 320 IPC (Clauses 7thly and 8thly).

Concurrent Findings: While the Court generally does not interfere with concurrent findings of fact, it will do so if the High Court has arrived at a finding in disregard of judicial processes or if the conclusions are manifestly perverse.