Convict in a Motor Accident Death Case Can Be Released on Probation if the Offence Carries Not More Than Two Years’ Punishment
Case Name: Mahadevanna D.M. v. State of Karnataka & Anr.
Citation: 2026 INSC 504
Date of Judgment/Order: 18 May 2026
Bench: Justice J.K. Maheshwari and Justice Atul S. Chandurkar
Held: The Supreme Court held that an accused convicted under Section 304-A IPC read with Section 134(b) and Section 187 of the Motor Vehicles Act, 1988 can be extended the benefit of Section 3 of the Probation of Offenders Act, 1958 where the offences carry punishment not exceeding two years. The Court clarified that once the benefit of probation is granted, Section 12 of the Probation of Offenders Act protects the convict from suffering disqualification arising from the conviction, including service-related consequences. The Court therefore confirmed the conviction but substituted the sentence with release after due admonition and payment of compensation to the deceased’s family.
Summary: The appellant, a BMTC bus driver, was convicted after a bus driven by him hit a pedestrian, Rangamma, on 27.12.2011, resulting in her death. The Trial Court convicted him under Sections 279 and 304-A IPC as well as Section 134(b) read with Section 187 of the Motor Vehicles Act, and the First Appellate Court affirmed the conviction. In revision, the Karnataka High Court set aside the conviction under Section 279 IPC but maintained the conviction under Section 304-A IPC and the Motor Vehicles Act provisions. Before the Supreme Court, the appellant sought the benefit of Section 3 of the Probation of Offenders Act, submitting that the maximum punishment under Section 304-A IPC is two years and that he was therefore eligible for release after admonition. The respondent did not object, subject to the amount of INR 5,00,000 deposited by the appellant being released as compensation to the family of the deceased. The Supreme Court accepted the submission and held that the appellant satisfied the statutory requirements for probation.
Decision: The Supreme Court disposed of the appeal by confirming the appellant’s conviction but directing that instead of serving the sentence, he be released after due admonition under Section 3 of the Probation of Offenders Act, 1958. The sentence of six months under Section 304-A IPC, fine of INR 3,000, and fine of INR 500 under Section 134(b) read with Section 187 of the Motor Vehicles Act were commuted into a compensation amount of INR 5,00,000 payable to the family of the deceased. The Court directed the Registry to release the deposited amount with accrued interest to the deceased’s family members within four weeks of receiving their bank account details and clarified that the fine and conviction shall not be treated as a disqualification for the appellant’s BMTC employment in view of Sections 3 and 12 of the Probation of Offenders Act.