Criminal Law — Sentencing — Reduction of sentence in revision — Improper exercise of jurisdiction — Proportionality and deterrence reaffirmed. Where the accused were convicted under Sections 307, 326 and 324 of the Indian Penal Code, 1860 for inflicting life-threatening stab injuries, reduction of sentence from three years’ rigorous imprisonment to the period already undergone (two months), merely on account of lapse of time and payment of compensation, is wholly unjustified. Sentencing must reflect proportionality, gravity of offence and societal impact. (Paras 18–22, 35–37).

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Criminal Law — Sentencing — Reduction of sentence in revision — Improper exercise of jurisdiction — Proportionality and deterrence reaffirmed.
Where the accused were convicted under Sections 307, 326 and 324 of the Indian Penal Code, 1860 for inflicting life-threatening stab injuries, reduction of sentence from three years’ rigorous imprisonment to the period already undergone (two months), merely on account of lapse of time and payment of compensation, is wholly unjustified. Sentencing must reflect proportionality, gravity of offence and societal impact. (Paras 18–22, 35–37).

Sentencing Policy — Lapse of time — Not by itself a mitigating factor.
Mere passage of time since the incident cannot, by itself, justify reduction of substantive sentence in serious offences. Sentencing requires holistic consideration of aggravating and mitigating factors, not isolated reliance on delay. (Paras 19, 27).

Victim Compensation — Nature — Not substitute for punishment.
Compensation under Section 357 of the Code of Criminal Procedure, 1973 (now Section 395 of the Bhartiya Nagarik Suraksha Sanhita, 2023) is restitutory in character and cannot substitute or dilute substantive punishment. Enhancement of fine coupled with reduction of imprisonment in grave offences risks conveying that criminal liability can be “purchased by money”. (Paras 29–32).

Relied on: Shivani Tyagi v. State of U.P. (Paras 33–34).

Undue Sympathy — Inadequate sentence — Undermines public confidence.
Courts must avoid undue sympathy leading to inadequate sentencing. Leniency in serious offences erodes public trust in the administration of justice and defeats deterrence. (Paras 23–27, 37).

Relied on:
State of M.P. v. Saleem
Hazara Singh v. Raj Kumar
State of M.P. v. Suresh

Sentencing — Foundational Principles — Enumerated factors.
The Court crystallised guiding principles to be followed while imposing or modifying sentence: proportionality; due consideration of facts and evidence; impact on society; and balanced assessment of aggravating and mitigating factors. (Para 34).

Revisional Jurisdiction — Improper interference with sentence.
High Court, while exercising revisional jurisdiction, cannot mechanically reduce sentence without cogent reasoning, especially where trial court has already imposed a sentence significantly below the statutory maximum (Section 307 IPC permitting imprisonment up to ten years). (Paras 37–38).

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RATIO DECIDENDI

The central ratio is that compensation to the victim or lapse of time cannot be treated as a substitute for substantive imprisonment in serious offences involving life-threatening injuries under Section 307 IPC. Sentencing must adhere to proportionality, deterrence, and societal interest. Reduction of sentence to period already undergone, without cogent reasoning and solely on sympathetic considerations, constitutes a serious error in law warranting interference.

A further ratio is that victim compensation is restitutory and supplementary; it cannot replace punitive sentencing. The criminal justice system does not permit offenders to neutralise imprisonment through monetary payment.

The Court reaffirmed that sentencing requires balancing aggravating and mitigating factors in a structured manner. Any mechanical or capricious reduction of sentence, particularly in revisional jurisdiction, undermines established criminal jurisprudence.

Accordingly, the Supreme Court set aside the High Court’s order reducing the sentence, restored the trial court’s sentence of three years’ rigorous imprisonment, and directed the accused to surrender and serve the remaining term.