KALARIMADATHIL UNNI vs STATE OF KERALA

The Supreme Court upheld the conviction of the appellants under Section 302 read with Section 34 IPC for murder, concluding that the act of asphyxiating the victim constituted an intentional infliction of bodily injury sufficient to cause death under the third clause of Section 300 IPC. The Court clarified that the distinction between murder and culpable homicide lies in the presence of mens rea, and in this case, the appellants' actions met the criteria for murder as the injury caused was objectively sufficient to result in death. The Court rejected the appellants' arguments that their actions amounted only to culpable homicide and that the necessary mens rea was not established.