Sattan Sahani vs State Of Bihar & Ors

The appellant was convicted under Section 307 IPC (attempt to murder), but the High Court modified the conviction to Section 326 IPC (voluntarily causing grievous hurt by dangerous weapons). The High Court reasoned that while the appellant inflicted a penetrating wound with a 'Bhala', the lack of multiple blows indicated an absence of intent to kill. The Supreme Court was called upon to review whether the nature of the injury and the weapon used justified the conviction for attempt to murder versus grievous hurt.