'Voluntarily' only means you must have specifically wanted the exact harmful outcome to happen.

Courts read Section 39 to also include situations where you knowingly used means likely to cause that outcome, even without specifically desiring it.

If you didn't target a specific person, you can't be said to have acted voluntarily.

The law focuses on whether you knew or had reason to believe your actions were likely to cause the effect, not whether you had a specific victim in mind.

Indian Penal Code, 1860

Section 39

repealed

Voluntarily

A person is said to cause an effect “voluntarily” when he causes it by means whereby he intended to cause it, or by means which, at the time of employing those means, he knew or had reason to believe to be likely to cause it.§

Why this exists

The IPC's framers, led by Lord Macaulay, wanted precise definitions for common words used throughout the Code so that courts would not have to guess their meaning in every case. 'Voluntarily' appears in many offences (like causing hurt or grievous hurt), and this section clarifies that the law punishes not just direct intention but also reckless or knowing conduct that predictably leads to harm. This closes a gap where someone might claim 'I didn't mean for that exact outcome' while having knowingly created a serious risk of it.

How courts read it

Indian courts have consistently held that 'voluntarily' under Section 39 covers both intention and knowledge-based recklessness, and is broader than 'intentionally' alone. Courts have applied this in cases involving causing hurt or grievous hurt, holding that an accused who uses a weapon or method knowing it is likely to cause serious injury can be held to have acted voluntarily, even without a specific desire for that outcome. The definition is frequently read together with substantive offences like Sections 321-322 (voluntarily causing hurt) to determine liability.

Common misconceptions

Myth: 'Voluntarily' only means you must have specifically wanted the exact harmful outcome to happen.
Fact: Courts read Section 39 to also include situations where you knowingly used means likely to cause that outcome, even without specifically desiring it.
Myth: If you didn't target a specific person, you can't be said to have acted voluntarily.
Fact: The law focuses on whether you knew or had reason to believe your actions were likely to cause the effect, not whether you had a specific victim in mind.