What was the final decision in this case?

The High Court upheld the conviction under Section 307 IPC for an acid attack and refused leniency. A fine of ₹3 lakh was directed for the victim.

Why did the Court rely on the victim’s statement?

The victim was an injured eyewitness. Such testimony receives high weight. It was consistent and supported by surrounding facts.

Why Section 307 IPC and not Section 326 IPC?

Throwing acid on the head and face showed knowledge that death could result. The act was pre-planned and satisfied the ingredients of Section 307.

Did recovery of the bottle matter?

No. The Court doubted the alleged recovery. Even without it, evidence proved the attempt to murder.

What larger message did the Court give?

Acid attacks are rising and must be curbed with heavy punishment to deter such crimes.

Naeem Khan @ Guddu v. State (2013)

Quick Summary

This case deals with an acid attack. The Court held that the act met the test of attempt to murder (Section 307 IPC). The victim’s direct and injured testimony was accepted. The attack was planned; the target areas were the head and face, showing knowledge of likely death. Conviction was upheld and a ₹3 lakh fine was ordered.

Issues

Should the accused be convicted under Section 307 IPC for attempt to murder in an acid attack?
Can the injured eyewitness testimony alone prove guilt?
Does the absence of name in the first information defeat later identification?

Rules

Section 307 IPC — Attempt to Murder

All ingredients of murder under Section 300 exist except the death. Intention or knowledge is judged from the weapon, target, injuries, and manner.

Injured Witness Rule

Evidence of an injured eyewitness has high probative value. Injury itself is a guarantee of presence at the scene.

Facts — Timeline

22 Apr 2005: Police got information that a girl was splashed with acid; PCR took her to hospital.

Hospital: Victim Laxmi had ~25% burns on face, eyes, chest, and arms.

Statement (S.161 CrPC): Laxmi, a sales rep at Khan Market, named Naeem Khan @ Guddu; motive rose from a rejected marriage proposal.

Attack narrative: Near Hanuman Road, a bike stopped; a woman (seen earlier with the appellant’s brother) threw acid on Laxmi’s chest and face.

Arrest & Recovery: Appellant arrested. An acid-stained bottle was allegedly found near a park; Court later doubted this recovery.

Trial: Conviction under Section 307 IPC based mainly on the victim’s ocular testimony.

Appeal: Defence said naming in S.161 was an afterthought. The case came before the High Court.

Arguments

Appellant

Name absent in first information → later naming is fabricated.
Victim’s version is unreliable; recovery doubtful.
At best, it is hurt (Section 326), not attempt to murder.

State

Victim is an injured eyewitness—credible and consistent.
Targeted the head/face with corrosive acid → knowledge of likely death.
Acts were pre-planned; motive proved beyond doubt.

Judgment

The High Court upheld the conviction under Section 307 IPC. It accepted the victim’s testimony, found the act pre-meditated, and held that throwing hydrochloric acid on the head/face implies knowledge of likely fatal consequence. The recovery of the bottle was disbelieved, but the remaining evidence was enough. The Court directed payment of ₹3,00,000 to the victim and recommended her case for compensation by the Delhi Legal Services Committee.

Ratio

Injured eyewitness testimony carries special weight and can sustain conviction if consistent.
Section 307 IPC is satisfied when intent/knowledge to cause death is seen from weapon, target, injuries, and manner.
Weak recovery does not defeat a strong case built on credible ocular and circumstantial evidence.

Why It Matters

The ruling shows how courts treat acid attacks with heavy hands. It clarifies when such acts cross from grievous hurt to attempt to murder, and why the law trusts injured eyewitnesses.

Key Takeaways

Head/face + acid = knowledge of likely death → S.307.
Injured witness evidence is powerful if consistent.
Pre-planning and motive support intent/knowledge.
Even if recovery fails, ocular + context can prove the case.

Mnemonic + 3-Step Hook

Mnemonic: HEAD • ACID • INTENT

HEAD was targeted → vital part.
ACID is lethal → severe burns.
INTENT shown by plan, motive, and conduct.

IRAC Outline

Issue: Does the attack amount to attempt to murder under Section 307 IPC?

Rule: Section 307 IPC (attempt); assess intention/knowledge using weapon, target, nature of injuries, motive, and manner.

Application: Acid thrown on head/face; victim’s credible injured testimony; clear motive and planning; recovery weak but not essential.

Conclusion: Conviction under Section 307 IPC sustained; no leniency; compensation awarded.

Glossary

Attempt to murder (S.307): Trying to cause death with intent/knowledge that would amount to murder if death occurs.
Injured eyewitness: A witness who was hurt in the same incident; courts usually trust such testimony.
Mens rea: The guilty mind—intent or knowledge behind the act.

FAQs

The Court affirmed Section 307 IPC conviction for the acid attack, declined leniency, and ordered ₹3 lakh to the victim with DLSA consideration.

She was an injured eyewitness. Her version was consistent and supported by the surrounding facts and motive.

The head/face targeting with corrosive acid showed knowledge of likely death, meeting the threshold for Section 307.

No. The Court doubted the recovery. Still, the ocular + contextual evidence proved the offence beyond reasonable doubt.

Rejection of the appellant’s marriage proposal caused resentment and led to the planned attack.