Pandurang V. State of Hyderabad AIR 1955 SC 216
In 1955, the case of Pandurang vs State of Hyderabad unfolded, eight years after Hyderabad's integration into the Indian Union. Pandurang stood accused, alongside others, of the brutal murder of Ramchander in 1951.
The primary legal issue revolved around Section 34 of the Indian Penal Code (IPC), which deals with "common intention" and criminal liability. The crux of the matter was whether Pandurang could be held equally responsible for the murder, given the uncertainties surrounding his specific intent and individual actions during the incident. Eyewitness testimonies varied, leaving Pandurang's role ambiguous.
Initially convicted under Section 302 (murder) and sentenced to death by lower courts, including the Hyderabad High Court, Pandurang's case underwent appellate review by the Supreme Court. The apex court acknowledged the severity of the crime but highlighted the lack of conclusive evidence establishing Pandurang's specific intent or his individual action causing the fatal injury.
Consequently, the court invoked Section 34 and ruled that Pandurang couldn't be held vicariously liable for the murder of Ramchander. Instead, he was convicted under Section 326 (grievous hurt) and sentenced to 10 years' rigorous imprisonment. This case underscores the challenges of determining culpability in cases where evidentiary ambiguities exist and the importance of adhering to due process in criminal justice proceedings.