Sunday, December 4, 2016

Causing Death of Quick Unborn Child

Section-312: Causing miscarriage.-  Whoever voluntarily causes a women with child to miscarry, shall, if such miscarriage be not caused in good faith for the purpose of saving the life of the women be punished with imprisonment of either description for a term which may extend to three years or with fine or both if the woman be quick with child shall be punished with imprisonment of either description for a term which may extend to seven years and shall also be liable to fine.
Explanation:   In fact the section deals with the causing of miscarriage with the consent of woman. The  Medical Termination of Pregnancy Act, 1971 provides for the termination of pregnancy by registered medical practitioners where in continuance would involve a risk to the life of pregnant woman or grave injury to her mental or physical health or where there is a substantial risk that if the child born, it would suffer from such physical or mental abnormalities as to be seriously handicapped. The termination of a pregnancy by a person who is not a registered medical practitioner will be an offence under Indian Penal Code-1800.  
                 Section-312 can ever apply to a pregnant woman herself who causes her won miscarriage. Good faith by itself is not enough. It has to be good faith for the purpose of saving. The life of mother or child and not otherwise.
Ingredients of this section:  
1.     At first it has to be proved that the women was pregnant.
2.     It had been done willingly.
3.     It had been done without good faith.
4.     Perception by the mother of the movements of the fetus.

Case References  :
v Meeru Bhatia Prasad VS State, 2002 Cr LJ1674(Del):  Section-312 can even apply to a pregnant women herself who causes her own miscarriage. Good faith for the purpose of saving life of mother and child and not otherwise.
v Akhil kumar VS State of M.P, 1992 Cr LJ 2029(MD): A woman had pregnancy of 24 weeks out of illicit relations and a doctor administered an injection for determination of the pregnancy but the women died next day without miscarriage . It was held that the act of doctor amounted to “Voluntarily Causing miscarriage” within the meaning of section-312, as the doctor presumed to know the possible effects of the medicine.
Section-313: Causing miscarriage without women’s consent.-  Whoever commits the offence defined in the last preceding section without consent of woman, whether the woman is quick with child or not, shall be punished with imprisonment for life or with imprisonment of either description for a term which may extend to 10 years and shall also be liable to fine.
Explanation:  Under the section the act should have been done without the consent of woman under it, the person procuring the abortion is alone punished under section-312 such person as well as the woman who causes herself to miscarry are both punished. When the accused woman kicked a pregnant woman in her abdomen resulting in miscarriage, her conviction under section-313 was sustained. It is a non-bailable offence.
Ingredients:
1)     The woman was pregnant.
2)     Miscarriage was done without her consent.
3)     Done by willing by.
4)     Without good faith.

Case References  :
v Tulsi Devi VS State of u.p – 1996: Under these section the act should have been done without the consent of the woman where the accused woman kicked a pregnant woman in her abdomen resulting in miscarriage, her conviction under section-313 was sustained.
Section-314: Death caused by act done with intent to cause miscarriage.- Whoever with intent to cause the miscarriage of a woman with child, dose any act which causes the death of such woman, shall be punished with imprisonment of either description for a term which may extend of ten years, and shall also be liable to fine.
 If the act done without woman’s consent: And if the act is done without the consent of the woman shall be punished either with imprisonment for life, or with punishment, or above mentioned.
Explanation: This section provides for the case where death occurs is causing miscarriage. The act of the accused must have been done with intent to cause the miscarriage of a woman with child.
Ingredients:
1)     She will be a pregnant woman.
2)     The miscarriage was done intentionally.
3)     For the miscarriage the woman caused death.
4)     Miscarriage was done without consent of woman.


Case References  :
v Surendra chauhan VS State of MP 2000 se.1436:  A person, name C, was alleged to have had illicit relations with the deceased woman. He took her to a doctor for the purpose  of aborting her of pregnancy. The doctor caused her death in that process. The doctor was not qualified for the purpose, nor his clinic was approved by the Government and was also not having the basic facilities for abortion. There was a concurrent finding that the act was done by the doctor in furtherance of the common intention with C. It was held that the conviction of C under this section read with section-34 was proper.

v Raqib Sheikh vs State 57 DLR 568.-  The prosecution having proved beyond reasonable doubt that the convict with intent to cause miscarriage of his deceased wife got a piece of plant-root placed in her uterus resulting in her death, the convict-husband is guilty of offence under section 314, Penal code.

Section-315: Act done  with intent to prevent child being born alive or to cause it to die after birth.- Whoever before the birth of any child does any act with the intention of thereby preventing that child from being born alive or causing it to due after its birth and does by such act prevent that child from being born alive or causes it the purpose of saving the life of the mother, be punished with imprisonment of either description for a term which may extend to 10 years or with fine or both.
Explanation: Any act done with the intention here mentioned which results in the destruction of the child’s life, whether before or after its birth, is made punishable.
Ingredients:
1)     The work was  done by the accused to prevent the birth of the child.
2)     The work was done intentionally.
3)     Good faith was absent.
4)     The accused was intended to cause death of the new born child.


Section-316:
Causing Death of Quick Unborn Child:-  Section-316 deals with causing death of quick unborn child by an act amounting to culpable homicide. It says,” Whoever does any act under such circumstances, that if he thereby caused death he would be guilty of culpable homicide, and does by such act cause the death of a quick unborn child, shall be punished with imprisonment of either description for a term which may extend to ten years ,shall also be liable to fine.”
Explanation:- This section punishes the causing of death of a quick unborn child by an act amounting to culpable homicide .That means, if a person strikes a pregnant woman and thereby cause death of her quick unborn child ,he will be guilty of the offence defined in this section if the blow was intended by him to cause the woman’s death or was one which he knew or had reason to believe to be likely to cause it. So, any act or omission of such a nature and done under such circumstances as would amount to the offence of culpable homicide, if the sufferer were a living person ,will if done to a quick unborn child whose death is caused by it, constitute the offence here punished.

Ingredients:-  From the above discussion ,in order to constitute any offence under this section requires the following ingredients-
(1)  That the woman was quick with child.
(2)  That the accused did an act to cause death of the child.
(3)  That the circumstances under which the act was done were such as to make the accused guilty of culpable homicide if death had been caused.
(4)  That such act caused the death of the quick unborn child.

Case References  :
v Murugan vs state of T.N.1991Cr.LJ 1680(mod); A husband striking his wife dead was held guilty of the offence under this section. The medical evidence showed that she was carrying a male child of 20 weeks. A foetus gets life after 12 weeks of conception.
v Jabbar air 1966 All 590; In order to constitute  offence this section the act complained of must be done with the necessary intention on knowledge which is specified in s.299 of the penal code. Merely because the death of the quick unborn child has resulted. The act would not amount to an offence under this section. The accused must be shown to have act under circumstances from which it can be inferred that he had the necessary intention or knowledge to cause death of the victim of his assault and which would amount to the offence of culpable homicide.
v (1970)36 Cut LT 711;  In order to constitute offence under this section it must be proved that such act did cause the death of quick unborn child. The unborn child should already have been quick insider the womb of the mother.
v 1971 Mad LW(Cri)240; Form the act of the accused, it must be possible to state that he had the necessary mens rea which renders him liable for  punishment for culpable homicide such an act must result in the death of a quick unborn child . Then this section is attracted. 


Section-317:  Exposure and abandonment of child under twelve years ,by parent or person having care of it:- Whoever being the father or mother of a child under the age of twelve years ,or having the care of such child , shall expose or leave such child in any place with the intention of wholly abandoning such child ,shall be punished with imprisonment of either description for a term which may extend to seven years or with fine or with both.
Explanation: This section is intended to prevent the abandonment or desertion by a parent of his or her children of tender years. In such a manner that the children not being able take care of themselves, may run the risk of dying or being injured. That means the offence under this section may be done by parent of illegitimate child or parents in distress and the gist of the offence is the exposure or leaving of such child in any place with the intention of abandoning it. In other words it is the desertion of the child by persons bound to support  and protect it or by one who has taken up on himself the duty of protecting it either by adoption or otherwise (18 Cri LJ98).

Ingredients: This section requires these four essentials to prove any offence under this section-
(1)  That the child is under twelve years of age.
(2)  That the accused person is the father or mother or the person having the care of that child.
(3)  That he exposed or left such child at the place in question.
(4)  That he so exposed or left the child with the intention of wholly abandoning it.



Case references:
v Where a woman immediately after giving birth to an illegitimate child threw it into a thorn bush and concealed the act without showing any solicitude for the child , she was guilty under this section .(AIR 1914 Upp Bur 22)
v Where a pregnant widow who has travelling by trail had labour pains at the station, went to the close-by public latrine on the platform delivered an illegitimate child and returned to the adjacent bridge for rest it was held that her conduct was consistent with innocence and she was given benefit of doubt(AIR 1920 Nay 181) .
v So, this section mainly meant to protect children below 12 years of age who are unable to take care of themselves. Abandonment and exposure of such children by their parents or by  persons  under whose care they have there for been made penal (1871)16 Suth WR 12(12)(DB) .



Section-318: Concealment of birth by secret disposal of dead body.-   Whoever, by secretly  burying or otherwise disposing of the dead body of a child whether such child die before or after  or during its birth, intentionally conceals or endeavors to conceal the birth of such child, shall be punished with imprisonment of either description for a term which may extend to two years, or with fine, or with both.
Explanation:   This section is intended to prevent infanticide. It is directed against concealment of birth of a child by secretly disposing of its body. This section deals with the secret burial of a child and applies only where one intentionally conceals the birth of a child from the world at large. The section contemplates that the child must have reached such a stage of   development and maturity that it may be born alive and be capable of living.(1906)3.Cri LJ432
Ingredients: This section requires the following elements to prove any offence under it. These are-
(1)  That there was the birth of the child.
(2)  That the child died either before, during or after its birth.
(3)  That the accused buried or otherwise disposed of the dead body.
(4)  That such burial or disposal of the body was secretly done.
(5)  That the accused thereby intentionally concealed, or endeavored to conceal, the birth of such child.
 Case References: 
v According to “Laibu (1898) Unrep Cr.C961” the offence under this section becomes complete when the birth i.e. the delivery of a child, dead or living is concealed by any means.
v When the accused gave her new born illegitimate dead child to a woman with instruction to dispose of it security and the latter carried out the instructions by throwing it into a river. It was held that the accused was no guilty of a substantive offence under this section, though the facts more appropriately came under the definition of abetment.(Baji (1895)Unrep Cr.C775) 
v  Where the body of a newborn child was found thrown in an open pit and the evidence was conflicting as to whether it was alive if dead at the time it was so thrown, the court held that the case should be considered as falling under this section and not under section 302 which would have been applicable if the child had been alive when it was thrown in the pit.(1906)3Cri LJ317
v The intention conceal or endeavor  to conceal the birth is necessary ingredient of the offence under this section.(1905)2 Cri LR(Cri)5

Book References:
(1)   Ratanlal and Dhirajlal.
(2)  Md. Zahurul Haque.
(3)  Md. Jeaul Hasan.

(4)  Bare Act


Submitted by:
Rama das -> 13219058.                         Hure Jannat-> 13209070.                      Taslima Akter->13219073.Fouzeya Nisat Jeba->13209035.Most. Hiramon khatun->13209056



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