Ravinder Singh v. State of Haryana & Ors.
Background
The complainant's brother, Duli Chand, was fatally assaulted by a group of men (including Pyare Lal, Ramesh @ Ravinder Pardeep, and others) with lathis and a "jailly," reportedly in retaliation for a panchayat complaint Duli Chand had made against them; he died of his injuries after days in a coma. The trial court convicted the accused under Section 304 Part II read with Section 149/148 IPC, but the Punjab and Haryana High Court, while upholding the conviction, reduced the sentence to time already served and imposed modest compensation amounts, to be paid to the victim's legal heirs. Both the complainant/State and the convicted accused cross-appealed to the Supreme Court over the adequacy of the sentence and compensation.
Decision Breakdown
The Supreme Court declined to disturb the High Court's reduction of the prison sentence to time already served, noting that more than 22 years had elapsed since the 1993 incident, two of the accused were students at the time, and one had since crossed 72 years of age: factors it found sufficient not to interfere with the High Court's exercise of sentencing discretion, even though it called the reduction "inadequate." However, on compensation, the Court held that the Rs. 25,000 fine imposed on each of several accused was too low given the loss of life involved, and enhanced it to Rs. 1,25,000 each (an additional Rs. 1,00,000 on top of what had already been deposited), with imprisonment to follow automatically if the enhanced amount was not paid within eight weeks; the fine on one deceased accused was left unchanged for disbursal to the heirs if already paid. Both connected appeals were disposed of on these terms, with the Court clarifying its order should not be treated as a sentencing precedent given the case's "peculiar facts."
Lesson Learnt
Appellate courts can revisit the adequacy of compensation awarded to a victim's family even while declining to revisit a reduced prison term, particularly where a long passage of time and the accused's personal circumstances (age, being students at the time) are weighed against the irreversible loss of life.