Emperor v. Mushnooru Suryanarayana Murthy (1912)

Quick Summary

A clerk secretly mixed a soluble poison in halva to kill a man whose life he had insured. The intended target ate a little and survived. A child, who later found the sweetmeat, ate it and died. The Court held: if you act with the intention to cause death, it is enough that someone dies due to that act—even if it is not the person you aimed at. The acquittal for the child’s death was set aside, and the accused was convicted of murder.

Issues

• Can the accused be held guilty of Rajalakshmi’s murder when she was not the intended victim?

Rules (Easy English)

Culpable Homicide (IPC §299): A person commits culpable homicide if they cause death by an act done with (a) intention to cause death, or (b) intention to cause such bodily injury as is likely to cause death, or (c) knowledge that the act is likely to cause death.

No need to target a specific person: The law does not demand that the accused intended to kill a particular named person. If death is caused to anyone because of the intentional deadly act, liability follows.

Facts (Timeline)

Arguments

Judgment

• The High Court set aside the acquittal for the child’s death.
• The accused was convicted for murder under IPC §302.
• Sentence: transportation for life (as recorded under then-applicable law, including reference to §303).

Ratio (Core Principle)

Where a person performs a lethal act with the intention to cause death, but a different person dies as a result of that very act, the mental element attaches to the outcome. The IPC does not insist that the intended and actual victim be the same person. Therefore, murder liability stands.

Why It Matters

• Clarifies that transferred intention logic works within IPC’s framework for homicide.
• Protects the public from deadly acts where the wrong person suffers the harm.
• Guides cases involving poisoning and indirect administration.

Key Takeaways

• No named-victim requirement: Intention to kill “someone” suffices.
• Chain of causation holds: Child’s act of eating discarded food was foreseeable after poisoning edible food.
• Attempt + Murder can coexist: Attempt on A; murder of B—based on the same lethal act.

Mnemonic + 3-Step Hook

Mnemonic: “HALVA → ANY LIFE”

1. Halva poisoned with intent to kill.
2. Another person dies from the same act.
3. Liability for murder attaches—no need for the same target.

IRAC Outline

Issue: Is the accused guilty of murder when a child, not the intended victim, died from the poisoned sweetmeat?

Rule: IPC §299/§302—intention to cause death or knowledge of likely death suffices; the victim need not be the specific person aimed at.

Application: The accused intended a lethal result by poisoning food; a child consumed it and died. The act and intention align with murder even though the person was not the intended target.

Conclusion: Conviction for murder sustained; acquittal set aside.

Glossary

Culpable Homicide

Causing death with intention or knowledge as defined in IPC §299.

Murder

A graver form of culpable homicide under IPC §300/§302.

Transferred Intention

Intention aimed at one person attaches when another person suffers the intended harm.

Chain of Causation

Link between the act and the death remains unbroken and foreseeable.

FAQs

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