Punjab & Haryana High Court Reduces Sentence of NDPS Convict to Period Already Undergone; Notes 16-Year Delay and Reformative Conduct

Case Name: Narender v. State of Haryana
Date of Judgment: October 31, 2025
Citation: CRA-S-2390-SB-2011
Bench: Hon’ble Mr. Justice Aman Chaudhary

Held: The Punjab & Haryana High Court upheld the conviction of the appellant under Section 20 of the Narcotic Drugs and Psychotropic Substances Act, 1985 but reduced his sentence to the period already undergone, citing his status as a first-time offender, long pendency of the case, and absence of any subsequent criminal conduct. Justice Aman Chaudhary emphasized the importance of reformative justice, observing that the appellant had suffered the ordeal of trial and incarceration for over 16 years and that further imprisonment would serve no useful purpose.

Summary: The appellant was convicted by the Special Court, Rohtak, for possessing 1 kg of charas and sentenced to three years’ rigorous imprisonment with a fine of ₹10,000. On appeal, he did not challenge the conviction but sought reduction of the sentence to the period already undergone (1 year, 6 months, and 27 days). The Court noted that the recovery was duly proved through credible police witnesses and supported by FSL evidence, leaving no ground to interfere with the conviction.

However, on the quantum of sentence, Justice Chaudhary relied on precedents including S.K. Sakkar @ Mannan v. State of West Bengal (2021) 4 SCC 483, Satish v. State of U.P. (2021) 14 SCC 580, and Naresh Kumar v. State of Haryana (CRA-S-796-SB-2005, decided on 24.02.2023) to highlight the judiciary’s reformative approach for first-time offenders. The Court reiterated that “a civilised society cannot be achieved only through punitive attitudes and vindictiveness; first-time offenders ought to be given a chance to reform and rebuild their lives.”

Decision: The appeal was partly allowed. The conviction was upheld, but the sentence was reduced to the period already undergone. The fine of ₹10,000 imposed by the trial court was maintained. The Court noted that the appellant had learned from his mistake and that a lenient approach was justified given his socio-economic condition and prolonged legal battle since 2009.