Supreme Court Restores Three-Year Sentence in Attempt to Murder Case, Holding Compensation Cannot Replace Punishment

Held: The Supreme Court held that compensation payable to a victim under Section 357 CrPC (now Section 395 BNSS) is restitutory in nature and cannot be treated as a substitute for substantive punishment, particularly in grave offences under Section 307 IPC; the Court held that the High Court acted in clear disregard of settled sentencing principles by reducing a three-year rigorous imprisonment sentence to the period already undergone solely on account of lapse of time and offer of compensation, and reiterated that sentencing must reflect proportionality, deterrence, societal impact, and a balanced consideration of aggravating and mitigating factors.

Summary: The case arose from an incident in 2009 where the accused stabbed the victim multiple times with knives, causing grievous and life-threatening injuries; the Trial Court convicted the private respondents under Sections 307, 326 and 324 IPC and sentenced them to three years’ rigorous imprisonment with fine, which was affirmed in appeal; in revision, the High Court confirmed conviction but reduced the sentence to the period already undergone (about two months) while enhancing fine to ₹1,00,000/- as compensation to the victim’s wife, relying primarily on lapse of time and the subsequent unrelated murder of the victim; the Supreme Court examined foundational principles of sentencing jurisprudence including proportionality, deterrence, societal confidence, and victimology, and held that undue sympathy and mechanical reduction of sentence undermine the administration of criminal justice; the Court emphasized that compensation is supplementary and cannot absolve the offender of penal consequences, cautioned against the growing trend of reducing custodial sentences in serious offences upon payment of money, and reiterated that mere passage of time is not a decisive mitigating factor in grave crimes involving life-threatening injuries.

Decision: The appeal was allowed; the judgment of the High Court modifying the sentence was set aside; the conviction and three-year rigorous imprisonment awarded by the Trial Court and affirmed in appeal were restored; the private respondents were directed to surrender before the Trial Court within four weeks to serve the remaining sentence after adjusting the period already undergone, failing which coercive steps were to be taken; pending applications stood disposed of.