Explain with the help of decided cases as to when Culpable Homicide under Section 299(3) will become Murder under Section 300(4) of Indian Penal Code.

Understanding Culpable Homicide and Murder

Section 299 of the IPC defines culpable homicide. It states that when a person causes the death of another, it is culpable homicide. However, it’s not murder unless it falls under one of the specific clauses of Section 300.

Section 300: Transforming Culpable Homicide into Murder

Section 300 outlines the conditions that elevate culpable homicide to murder. These conditions can be broadly categorized into three groups:

1. Acts Committed in the ‘Heat of Passion’

If death is caused by acts committed in the heat of passion due to provocation, it becomes murder. However, the provocation must be sufficient to deprive a reasonable man of the use of his faculties. The accused must also have acted without sufficient time to reflect on the consequences. The case of *Ram Singh v. State of Karnataka* (1984) clarified the requirement of “sufficient cooling time” for the passion to subside.

2. Acts of Particular Types

Section 300(2) lists specific acts that, if done with the intention to cause death or with the knowledge that they would likely cause death, constitute murder. These acts include:

• Poisoning
• Insanity
• Doing acts with explosives
• Using a rope or chain to restrict breathing
• Depriving a person of sensation which incapacitates them and then causing death

3. Acts Done with Specific Intent or Knowledge

Section 300(4) is the most relevant to this question. It states that if death is caused by doing any act which, if done under Section 300(1) or 301 or 302, would be murder, then the act would be considered murder. Essentially, it focuses on the 'mode' and 'intention' behind the act.

To trigger Section 300(4), two conditions must be met:

1. The act must be one that, if done with the intention to cause death, would be murder. This refers to the 'mode' of the act.
2. The act must be done with the specific intention to cause death or with the knowledge that death would be a highly probable consequence. This refers to the 'intent' of the act.

The case of *State of Punjab v. Satvir Singh* (1982) is pivotal here. The Supreme Court held that the prosecution must prove, beyond a reasonable doubt, that the accused had the requisite intention to cause death or knowledge that death would be a highly probable consequence. The court emphasized that mere negligence or rashness does not suffice.

Illustrative Example: Section 300(4) in Action

Consider a scenario where 'A' intentionally hits 'B' on the head with a brick, causing his death. While 'A' might not have intended to kill 'B' immediately, the act of hitting someone on the head with a brick is an act that, if done with the intention to kill, would be murder (Section 300(1)). Therefore, under Section 300(4), 'A' can be convicted of murder if it's proven that he knew that hitting 'B' on the head with a brick would likely cause death.

Comparison Table: Culpable Homicide vs. Murder (Section 300(4))

Feature	Culpable Homicide (Section 299)	Murder (Section 300(4))
Intent	May or may not involve intent to cause death	Requires specific intent to cause death or knowledge that death would be a highly probable consequence.
Mode of Act	Any act causing death	The act must be one that, if done with the intention to cause death, would be murder.
Punishment	Imprisonment for life or imprisonment for a term which may extend to ten years, and shall also be liable to fine.	Imprisonment for life, or imprisonment for a term which may extend to ten years, and shall also be liable to fine.