Punjab & Haryana High Court Modifies Sentence in Rash Driving Case While Upholding Conviction

Case Name: Sanjay v. State of Haryana
Date of Judgment: October 13, 2025
Citation: CRR-2406-2025 (O&M)
Bench: Hon’ble Mr. Justice Vinod S. Bhardwaj

Held: The Punjab & Haryana High Court upheld the conviction of the petitioner for causing death by rash and negligent driving but modified the sentence imposed by the lower courts. Justice Vinod S. Bhardwaj held that while the concurrent findings of guilt recorded by the trial and appellate courts were well-founded and supported by evidence, the punishment required slight reduction considering the petitioner’s socio-economic condition. The Court reiterated that deterrence and proportionality remain central to sentencing policy, but mitigating factors such as age, family circumstances, and absence of intoxication must also be weighed.

Summary: The petitioner, Sanjay, was convicted by the Judicial Magistrate First Class, Hisar, under Sections 279, 337, 304-A, and 427 IPC, along with Sections 181 and 192 of the Motor Vehicles Act, for causing the death of one Balbir by rash and negligent driving of a pick-up van. He was sentenced to varying terms of imprisonment, including two years’ rigorous imprisonment under Section 304-A IPC. The conviction and sentence were affirmed by the Additional Sessions Judge, Hisar, leading the petitioner to file the present revision.

It was contended that the deceased’s death was not directly attributable to the accident since he left multiple hospitals against medical advice, creating a break in causal connection. The petitioner also disputed his identification, arguing that no test identification parade was conducted and that the witnesses were related to the deceased. The State opposed the petition, asserting that the deceased remained under continuous treatment from the date of the accident until his death, and the petitioner himself was the registered owner of the offending vehicle.

Justice Bhardwaj rejected the petitioner’s arguments, holding that the evidence clearly established the petitioner’s identity as the driver, supported by eyewitness testimony, site plan, and mechanical inspection of the damaged vehicle. The Court observed that both the trial and appellate courts had properly appreciated the evidence and their findings were neither perverse nor illegal. However, considering the petitioner’s financial hardship, his role as sole breadwinner for four minor children, and the compensation already awarded to the victim’s family, the Court found it appropriate to reduce the custodial sentence.

Decision: The High Court upheld the conviction under Sections 279, 337, 304-A, and 427 IPC but modified the sentence of rigorous imprisonment under Section 304-A IPC from two years to eighteen months, maintaining the fine of ₹3,000. All other sentences were to run concurrently, and the compensation awarded under Section 357(3) Cr.P.C. was sustained. The revision petition was thus partly allowed.