Supreme Court Overturns High Court’s Modification of Conviction in Murder Case

The Supreme Court of India recently delivered a significant judgment in the case of Ramyash @ Lal Bahadur versus The State of Uttar Pradesh and Another, setting aside the Allahabad High Court’s modification of its earlier judgment. The case revolves around a violent altercation that resulted in the death of Jeet Lal and injuries to several family members. The Supreme Court’s ruling underscores the limitations on judicial review under Section 362 of the Code of Criminal Procedure (Cr.P.C.), which prohibits courts from altering or reviewing judgments except to correct clerical or arithmetical errors.

The incident dates back to May 13, 2012, when a land dispute between the families of the appellant and the accused escalated into a violent confrontation. The accused, armed with weapons like gandasi, danda, and lathi, allegedly assaulted the appellant and his family members. The appellant’s father, Jeet Lal, succumbed to his injuries, leading to the addition of Section 304 of the Indian Penal Code (IPC) to the First Information Report (FIR). The trial court convicted the accused under Sections 302 (murder) and other relevant provisions of the IPC, sentencing them to life imprisonment.

The accused appealed to the Allahabad High Court, which initially dismissed their appeals and upheld the trial court’s judgment. However, the High Court later allowed a Correction Application filed by the accused, modifying its earlier judgment and converting the conviction from Section 302 to Section 304 Part II of the IPC. This decision reduced the sentences of the accused, with Bhupendra Singh receiving 10 years of rigorous imprisonment and Moti Lal and Prahlad receiving 5 years each.

Read also: https://judgmentlibrary.com/supreme-court-sets-aside-high-court-order-on-sc-st-act-case-clarifies-cognizance-procedure/

The Supreme Court, in its judgment, critically examined the High Court’s actions. Justice B.R. Gavai, delivering the judgment, emphasized that the High Court’s modification went beyond the scope of Section 362 of the Cr.P.C. The Court noted that the High Court had not merely corrected a clerical error but had substantially altered its earlier reasoning and conclusions. The Supreme Court observed, “Under Section 362 of Cr.P.C., once the judgment and final order is signed disposing of a case, no Court is allowed to alter or review the same except to correct a clerical or arithmetical error.”

The Supreme Court referenced its earlier decision in Smt. Sooraj Devi v. Pyare Lal and Another, where it clarified that a clerical or arithmetical error is one that arises from an accidental slip or omission and does not involve a change in the court’s intended decision. The Court also cited Naresh and Others v. State of Uttar Pradesh, where a similar attempt by the High Court to alter a conviction was struck down as contrary to Section 362 of the Cr.P.C.

The Supreme Court allowed the appeals filed by the complainant, Ramyash @ Lal Bahadur, and dismissed the appeal filed by the accused, Bhupendra Singh. The Court quashed the High Court’s impugned judgment, restoring the original conviction and sentence under Section 302 of the IPC. The accused were directed to surrender before the Chief Judicial Magistrate, Jaunpur, within four weeks to serve the remaining period of their sentence. However, the Court reserved the right of the accused to challenge the High Court’s initial judgment dated May 21, 2018, on its merits.

This judgment serves as a reminder of the strict limitations imposed by Section 362 of the Cr.P.C. and reinforces the principle that judicial decisions, once finalized, cannot be altered except in narrowly defined circumstances. The Supreme Court’s intervention ensures that the integrity of the judicial process is upheld and that victims of violent crimes receive justice.

Read also: https://judgmentlibrary.com/supreme-court-quashes-dowry-case-against-husbands-relatives-key-legal-analysis/

Petitioner Name: Ramyash @ Lal Bahadur.
Respondent Name: The State of Uttar Pradesh and Another.
Judgment By: Justice B.R. Gavai, Justice Augustine George Masih.
Place Of Incident: Jaunpur, Uttar Pradesh.
Judgment Date: 23-04-2025.
Result: allowed.

Don’t miss out on the full details! Download the complete judgment in PDF format below and gain valuable insights instantly!

Download Judgment: ramyash-@-lal-bahadu-vs-the-state-of-uttar-p-supreme-court-of-india-judgment-dated-23-04-2025.pdf