Trial, conviction & appeal history

The trial court noted cardiac arrest under stress as contributory and acquitted. High Court relied on medical testimony and autopsy to hold that the subdural haemorrhage caused death and convicted. Three criminal appeals reached the Supreme Court — filed by the two accused and the informant — and the matter required analysis of both guilt and adequacy of sentence.

Supreme Court findings — guilt

The Supreme Court recognised investigation lapses but emphasised that acquittal or conviction cannot rest on mere doubts alone. After weighing medical evidence and witness testimony, the Court concluded that the material established only a case of voluntary hurt (Section 323 IPC) against respondent No.1 — not culpable homicide beyond reasonable doubt. The Court also flagged societal tendency to be lenient toward celebrities but retained the conviction under Section 323.

Review of sentence — key reasoning

The Court entertained a review limited to sentencing. The original sentence (imposed earlier) was a fine of ₹1,000. The Supreme Court scrutinised whether that sentence was manifestly inadequate in view of:

• Respondent No.1’s physical fitness and stature (an international cricketer), and the effect a blow from such a person could have.
• The fact that the victim was a 65‑year‑old man — a considerably weaker physical frame compared to respondent No.1.
• The accepted fact of a single blow to the head and resulting subdural haemorrhage; the Court considered this a material aspect insufficiently accounted for during sentencing.

“The punishment must be proportionate to the atrocity and brutality of the crime… a disproportionately light punishment humiliates and frustrates a victim and erodes confidence in the criminal justice system.”

Taking these considerations, the Supreme Court found an error apparent on the face of the record as to sentence and ordered that, in addition to the fine already imposed, respondent No.1 undergo one year rigorous imprisonment.

Legal principles & exam points

1. Standard of proof: Criminal guilt must be proved beyond reasonable doubt; where doubt persists, conviction cannot be sustained.
2. Sentencing proportionality: Sentences must be proportionate to the seriousness of the offense and the manner of its commission; unduly lenient sentences undermine public confidence.
3. Role of offender’s capacity: Physical condition, status and capacity of an offender are relevant at the stage of sentencing — a blow inflicted by a physically powerful person may have greater consequences.
4. Review jurisdiction: Where sentencing shows a manifest inadequacy in view of material facts, review to enhance sentence can be justified.

Conclusion

The Supreme Court allowed the limited review on sentencing and enhanced punishment: in addition to the previously imposed fine, the Court sentenced respondent No.1 to one year rigorous imprisonment. The decision is significant for sentencing jurisprudence and is a useful study note for aspirants preparing for judicial services and criminal law papers.

Study tip: For judicial exam answers, briefly set out facts, the Court’s reasoning on proof vs. sentence, cite relevant sections (e.g., Section 323 IPC), and mention how sentencing principles were applied here.