Rameela v. State of Rajasthan: SC Restores Murder Conviction

Septicemia Death 16 Days After Stabbing Was Murder: Supreme Court Restores Section 302 IPC Conviction

Rameela w/o Late Mahendra v. State of Rajasthan & Anr. Decided 5 November 2026

Published: 11 November 2026 · NyayVidhan · 3 min read

In Rameela v. State of Rajasthan & Anr., the Supreme Court restored a trial court's murder conviction under Section 302 of the IPC, setting aside a Rajasthan High Court judgment of 18.05.2026 that had altered it to Section 304 Part II because the deceased died 16 days after being stabbed. Applying Maniklal Sahu v. State of Chhattisgarh, the Court held that, if the cause of death was septicemia, it was a result of nothing but the stab wounds (paras 12-16).

Key holdings

The High Court erred in altering the conviction from Section 302 to Section 304 Part II because death came 16 days after the stabbing (paras 8, 11-12).

The issue is settled by Maniklal Sahu v. State of Chhattisgarh, 2025 SCC OnLine SC 1960 (paras 12-13).

If the cause of death was septicemia, it was a result of nothing but the stab wounds (para 14).

The death was the direct result of the injuries: murder punishable under Section 302 of the IPC (para 15).

The trial court's conviction and sentence of life imprisonment with fine were restored (paras 7, 16).

Judgment digest by NyayVidhan: a summary of the court's judgment, not its text. The judgment itself is the authoritative version.

Brief Facts

Respondent no. 2 was tried before the Special Judge under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, in Special Case No. 50 of 2021, under Section 302 of the IPC and Section 3(2)(v) of the 1989 Act (para 3). The prosecution case was that, armed with a knife, he came to the house of the deceased, picked up an altercation and is alleged to have inflicted stab wounds; the deceased succumbed to the injuries after 16 days in hospital (paras 4-5). The trial court convicted him for murder (para 7). The Rajasthan High Court at Jodhpur altered the conviction to Section 304 Part II, and the deceased's wife, the de facto complainant, appealed (paras 2, 9).

Court's Findings

The High Court had taken the view that, since the deceased succumbed after 16 days, the accused had no intention to cause death; its judgment could also be understood as saying that septicemia, the cause of death in the post-mortem, was not the direct result of the injuries (para 8). The Supreme Court held that the High Court ‘committed an egregious error’, the issue having been settled in Maniklal Sahu v. State of Chhattisgarh, 2025 SCC OnLine SC 1960 (para 12). It reproduced the principles laid down there: where intended injuries were sufficient to cause death in the ordinary course of nature, death after septicaemia or other complications is still murder; the possibility that skilful medical treatment might prevent the fatal result is ‘wholly irrelevant’; and a person is liable for causing death if the supervening causes are attributable to the injuries (para 13). Applying them, the Court said that if the cause of death was septicemia, it was ‘a result of nothing but the stab wounds’ (para 14). The death was the direct result of the injuries: a case of murder punishable under Section 302 (para 15).

Legal Principle

A gap of days between a stabbing and death, with septicaemia as the post-mortem cause of death, did not justify altering a murder conviction to Section 304 Part II of the IPC where the septicaemia resulted from the stab wounds; the death was the direct result of the injuries and is murder under Section 302 (paras 12-15).

NyayVidhan's view · Practice note

Why It Matters

For complainants and prosecutors, this order is a short, direct application of Maniklal Sahu v. State of Chhattisgarh: where a stabbing victim dies days later and the post-mortem records septicaemia, the delay alone does not take the case out of Section 302 of the IPC if the complication was a result of the injuries (paras 12-15). The appeal was brought by the deceased's wife as the de facto complainant, and it restored the trial court's conviction and sentence (paras 2, 9, 16). Readers should note what the order does not say: it does not discuss the eyewitness evidence or say how the trial court dealt with the charge under Section 3(2)(v) of the 1989 Act (paras 3, 6-7).

Editorial comment by the NyayVidhan Editorial Desk. It is not part of the Court's judgment and is not legal advice.

Precedents Relied Upon

Maniklal Sahu v. State of Chhattisgarh 2025 SCC OnLine SC 1960
Applied Discussed at ¶ 12, 13
Held to have settled the issue: the Court reproduced its paragraph 69 principles on death delayed by septicaemia or other complications (still murder where the injuries were intended and sufficient in the ordinary course of nature, or imminently dangerous to life; supervening causes attributable to the injuries leave the assailant liable for the death) and applied them to hold that the septicemia resulted from the stab wounds and the offence was murder under Section 302.