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Manohar Singh v. State of Rajasthan and Ors.

Criminal Appeal · Neutral citation not assigned (Criminal Appeal No. 99 of 2015)Decided 16 Jan 2015
Criminal Appeal No. 99 of 2015
Justice T.S. Thakur · Justice Adarsh Kumar Goel

Background

In 1980, a group of 13 people assaulted the complainant, Manohar Singh, and three others over a dispute about possession of agricultural land, causing the complainant as many as 10 injuries, including incised and bone-deep wounds. The trial court convicted several of the accused of serious offences, but on appeal, the Sessions Court reduced the convictions to the lesser offence of simple hurt and granted the accused probation (subject to a modest fine), and the High Court declined to interfere with this on revision by the complainant.

Decision Breakdown

The Supreme Court held that, 35 years after the incident, it would not be appropriate to impose fresh imprisonment on the accused, but found that the lower courts had failed to properly focus on compensating the injured victim, which it described as now integral to just sentencing. Reviewing a line of its own precedents on Sections 357 and 357-A of the Code of Criminal Procedure, the Court held that courts have a near-mandatory duty to apply their minds to victim compensation in every criminal case, considering the medical and other losses actually suffered by the victim. Given the extent and severity of Manohar Singh's injuries, the Court set aside the earlier small fine and directed the surviving accused to pay him Rs. 50,000 as compensation within two months, failing which they would face three months' imprisonment.

Lesson Learnt

Indian courts are expected to actively consider and award meaningful compensation to crime victims under Sections 357/357-A CrPC, not just decide on punishment for the accused, and this duty to compensate the victim can survive and be enforced even many years after the original offence.

Official source (sci.gov.in)View Judgment (PDF)

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