The section does not protect the police, if in the event leading up to the arrest, the officer concerned causes the death of the suspect, who is not accused of an offence punishable with death or with imprisonment for life. In Karam Singh v Haradayal Singh, 1979 Cr LJ 1211, where fire was opened to disperse an unlawful assembly and death of an innocent person was caused, section 46 could not be invoked for the protection of the police officers.
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