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Legal Case Shots

Court judgements broken down into the case type, how the decision played out, and the lesson worth remembering, with the full judgement available as a PDF.

Frequently asked questions

Is this suitable for use in legal research and court filings?+

Legal Case Shots is built to help you quickly identify and understand relevant precedent. For citation in pleadings or filings, always verify against the full judgment PDF and current citation format (e.g., 2026 INSC ___).

How is a "lesson learnt" different from the judgment's holding?+

The holding is what the court legally decided. The lesson learnt translates that into a practical takeaway: what a lawyer should factor into case strategy or client advice as a result of this precedent.

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What is Legal Case Shots?+

Legal Case Shots is a searchable database of Supreme Court of India judgments, each broken down into the case type, the court's key holding, and a practical lesson learnt, with the full judgment available as a PDF for citation or deeper reading.

Criminal LawSupreme Court of India

Razia Khan vs. The State of M.P.

Criminal Appeal · 2023 INSC 667Decided 3 Aug 2023
Criminal Appeal No. 2259 of 2023
Abhay S. Oka · Sanjay Karol

Background

In December 1992, the appellant, a social worker, forced her way into the chamber of a Directorate of Women and Child Development official who was holding an official meeting, threw a file at him and abused him. When another officer present tried to intervene, the appellant pushed her, fracturing her finger. The Sessions Court convicted the appellant under Sections 333, 353 and 451 IPC and the High Court upheld the conviction while reducing the sentence to six months' rigorous imprisonment on each count. The Supreme Court had earlier limited its notice only to the question of sentence, not the conviction itself.

Decision Breakdown

The Supreme Court confirmed the conviction but further reduced the sentence, weighing several cumulative factors: the incident was over 30 years old, the appellant remained on bail throughout with no further misconduct, and she was now a 62-year-old woman. Since the offence under Section 333 IPC carried a mandatory minimum of both imprisonment and fine, she could not be let off with only a fine, but the Court brought the sentences down to short terms of simple imprisonment (one month each, running concurrently) along with fines totalling ₹75,000, part of which was directed to be paid to the injured witness as compensation.

Lesson Learnt

Even where a conviction for assaulting or obstructing a public servant is upheld, courts retain discretion to significantly moderate the sentence based on factors like extreme delay, the accused's conduct during that time, age and other mitigating circumstances, sentencing is not mechanical once guilt is established.

Official source (sci.gov.in)View Judgment (PDF)
Razia Khan vs. The State of M.P. – Legal Case Shots | LegalAware