In the case of Emperor vs Mushnooru Suryanarayana Murthy on 2 January 1912, the Madras High Court was faced with a complex legal question involving the interpretation of the Indian Penal Code. The case revolved around a man named Suryanarayana Murthy, who was accused of murdering a young girl named Rajalakshmi through poisoning.
Facts of the Case
Suryanarayana Murthy, the accused, was charged with the murder of Rajalakshmi and the attempted murder of Appala Narasimhulu by administering poison. The accused had insured Narasimhulu’s life without his knowledge and intended to kill him to claim the insurance money. He gave Narasimhulu a sweetmeat (halva) laced with a poison containing arsenic and mercury. Narasimhulu ate a portion of the sweetmeat and threw the rest away. Rajalakshmi, who was the niece of the accused, picked up the discarded sweetmeat and ate it, also sharing it with another child. Both children died from the effects of the poison, while Narasimhulu survived.
Issues
The primary issue before the court was whether Suryanarayana Murthy could be held guilty of the murder of Rajalakshmi, even though he did not intend to cause her death. The court had to interpret Sections 299 to 301 of the Indian Penal Code, which define culpable homicide and murder, and determine whether the accused’s actions could be considered as having “caused” Rajalakshmi’s death.
Court’s Observations
The court observed that the accused did cause the death of Rajalakshmi and is guilty of her murder. The court noted that the accused intended to cause the death of Narasimhulu, and in order to do so, he concealed poison in a sweetmeat and gave it to him to eat. It was these acts of the accused which caused the death of the girl, even though her own action in picking up and eating the poison contributed to the result.
The court further observed that the Indian Penal Code does not require that the offender should intend to kill (or know himself to be likely to kill) any particular person. It is enough if he “causes the death” of anyone by doing an act with the intention of “causing death” to anyone, whether the person intended to be killed or anyone else.
The court also noted that it is not necessary that the death should be caused directly by the action of the offender, without contributory action by the person whose death is caused or by some other person. The court cited the illustrations provided in the Indian Penal Code to support this interpretation.
Conclusion
The court concluded that the accused in this case is guilty of murder as defined in Sections 299 to 301 of the Indian Penal Code. The court noted that the accused’s action was the efficient cause of the girl’s death, even though her own action in picking up and eating the poison was also necessary to effect her death. The court held that the accused’s criminal intention in attempting to kill Narasimhulu made the act done and the consequence which followed from it an offence, even though he did not intend to cause the death of the girl.
The court allowed the appeal by the Government and convicted the accused of the murder of Rajalakshmi. However, considering the circumstances, the court did not impose a sentence of death, even though it would have been appropriate if the accused had been convicted of murder at the original trial.