Culpable negligence is a pivotal concept within criminal jurisprudence, encapsulating the spectrum of carelessness that transcends mere inadvertence, thus meriting penal consequences. This article elucidates the doctrine of culpable negligence, examining its legal underpinnings, statutory embodiment under Section 304A of the Indian Penal Code (IPC), and Section 106 of the Bharatiya Nyaya Sanhita, 2023 (BNS). Through meticulous analysis of pertinent case law, including Suleman Rehiman Mulani vs. State of Maharashtra (1968) 3 SCR 485, and Jacob Mathew vs. State of Punjab (2005) 6 SCC 1, this discourse aims to delineate the contours of culpable negligence, exploring its jurisprudential evolution and contemporary relevance.

Introduction
Negligence, in its simplest form, signifies a breach of duty of care, culminating in harm. However, culpable negligence occupies a distinct echelon within the legal hierarchy, characterized by a degree of recklessness or gross negligence that manifests in criminal liability. Under Section 304A of the IPC, culpable negligence is enshrined as causing death by negligence, stipulating imprisonment or fine as punitive measures. The Bharatiya Nyaya Sanhita, 2023, via Section 106, perpetuates this provision, underscoring the sustained legislative intent to deter egregious neglect resulting in fatality.

Legal Framework:
Section 304A, Indian Penal Code
Section 304A of the IPC is the statutory nucleus for offences pertaining to death by negligence. The provision penalizes any person who causes the death of another by a rash or negligent act not amounting to culpable homicide. The jurisprudence of Section 304A emphasizes the distinction between mere carelessness and a gross departure from the standard of care expected, which constitutes culpable negligence.

Section 106, Bharatiya Nyaya Sanhita, 2023
The Bharatiya Nyaya Sanhita, 2023, mirrors the principles of Section 304A, encapsulating the essence of culpable negligence under Section 106. This statutory alignment signifies a continuity in legislative approach towards addressing gross negligence leading to fatal outcomes.

Jurisprudential Analysis
Case Law

• Suleman Rehiman Mulani vs. State of Maharashtra (1968) 3 SCR 485: In Suleman Rehiman Mulani, the Supreme Court of India elucidated the parameters of culpable negligence, emphasizing that mere negligence, devoid of recklessness or indifference towards human life, does not suffice for criminal liability under Section 304A. The Court underscored the necessity of proving a gross degree of negligence or rashness, which the ordinary prudent man would avoid, to establish culpable negligence.
• Jacob Mathew vs. State of Punjab (2005) 6 SCC 1: In the seminal case of Jacob Mathew, the Supreme Court delineated the concept of negligence within the medical profession, differentiating between ordinary negligence and culpable negligence. The Court opined that for negligence to transcend into the realm of criminality, it must exhibit a gross or flagrant character, demonstrating a recklessness tantamount to indifference towards the consequences. This case significantly shaped the understanding of culpable negligence, particularly in professional contexts.

Jurisprudential Evolution
The evolution of culpable negligence in Indian jurisprudence reflects a meticulous balancing act between penalizing gross neglect and safeguarding individuals from unjust prosecution for inadvertent lapses. The judicial pronouncements consistently underscore the necessity of establishing a high threshold of negligence, characterized by grossness or recklessness, to invoke criminal liability.

Conclusion
Culpable negligence remains a cornerstone of criminal liability for acts of gross negligence resulting in death. The statutory provisions under Section 304A of the IPC and Section 106 of the Bharatiya Nyaya Sanhita, 2023, underscore the legislative intent to deter and penalize egregious negligence. Through a robust jurisprudential framework, epitomized by landmark cases such as Suleman Rehiman Mulani and Jacob Mathew, the judiciary continues to refine the contours of culpable negligence, ensuring that only those acts exhibiting gross disregard for human life attract criminal sanctions.

End Notes:

• Suleman Rehiman Mulani vs. State of Maharashtra (1968) 3 SCR 485.
• Jacob Mathew vs. State of Punjab (2005) 6 SCC 1.
• Indian Penal Code, 1860, § 304A.
• Bharatiya Nyaya Sanhita, 2023, § 106.