STATE OF PUNJAB vs SARWAN SINGH

The Supreme Court held that the respondent's actions constituted murder under Section 302 IPC, as the injuries inflicted were with a heavy weapon (gandasa) and resulted in the death of Santokh Singh. The Court found that the lower courts erred in applying Exception (4) to Section 300 IPC, which pertains to culpable homicide not amounting to murder, as the respondent acted with undue advantage and in a cruel manner. Consequently, the conviction under Section 304 IPC was set aside, and the respondent was sentenced to life imprisonment under Section 302 IPC.