Ravada Sasikala v. State of Andhra Pradesh & Anr.

Criminal Appeal · Neutral citation not assigned (Criminal Appeal Nos. 406-407 of 2017)Decided 27 Feb 2017
Criminal Appeal Nos. 406-407 of 2017
Justice Dipak Misra · Justice R. Banumathi

Background

The accused, after his marriage proposal to the appellant was rejected by her family, trespassed into her house and poured acid over her head, causing disfigurement. The trial court convicted him under Sections 326 and 448 IPC and sentenced him to one year's rigorous imprisonment plus a fine, but the High Court, while upholding the conviction, reduced his sentence to the 30 days he had already spent in custody. The victim appealed to the Supreme Court solely against the inadequacy of this reduced sentence.

Decision Breakdown

The Supreme Court held that the High Court's drastic reduction of the sentence to time already served was wholly disproportionate to the gravity of an acid attack and reflected misplaced leniency rather than sound sentencing principles. Surveying a long line of precedent on sentencing, including that punishment must be proportionate to the offence and must account for the victim's and society's interests, not just the convict's, the Court restored the trial court's original sentence under Section 326 IPC. It also separately directed the convict to pay Rs. 50,000 and the State of Andhra Pradesh to pay Rs. 3 lakh as victim compensation, drawing on the Court's earlier directions in acid-attack compensation cases.

Lesson Learnt

Appellate and High Courts cannot treat "mercy" as a substitute for proportionate punishment in serious violent crimes; victims (not just the State) have standing to appeal against an unduly lenient sentence, and courts must also independently consider victim compensation under the CrPC alongside the criminal sentence itself.

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