Question
In the landmark caseĀ State of Andhra Pradesh v.
Rayavarapu Punnayya & Another (1976), the Supreme Court laid down comprehensive principles for distinguishing culpable homicide from murder. The Court established that: Which principle regarding the distinction between culpable homicide and murder was established in this landmark judgment?Solution
In State of Andhra Pradesh v. Rayavarapu Punnayya & Another (1976), the Supreme Court held that "culpable homicide" is the genus and "murder" is the specie. This foundational principle means that all murders are forms of culpable homicide, but not all culpable homicides constitute murder. The Court emphasized that the degree of probability of death occurringāi.e., the likelihood and imminence of deathāis the distinguishing factor. Acts committed with special characteristics (intention, knowledge, and severity of injury) elevate culpable homicide to murder. This 3-step inquiry (whether death was caused, whether it amounts to culpable homicide, whether it falls within murder's definition) has guided Indian criminal jurisprudence.
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