Supreme Court Modifies Sentence in Fatal Road Accident Case, Awards Rs 10 Lakh Compensation to Victim’s Family

The Supreme Court of India recently delivered a significant judgment in the case of Sanjay Colaro vs State of Karnataka, modifying the sentence in a fatal road accident case while upholding the conviction. The judgment, delivered by Justices Vikram Nath and K.V. Viswanathan on April 21, 2025, balanced the principles of justice by upholding the conviction under Sections 279 (rash driving) and 304A (death by negligence) of IPC, while replacing the six-month imprisonment with a compensation of Rs 10 lakh to be paid to the victim’s family.

The case involved a tragic accident that occurred on March 29, 2008, near Ramadevara Pada on Bengaluru-Mysuru Road, where the appellant’s car hit and killed pedestrian Chaluvappa. The trial court had convicted the appellant and sentenced him to six months imprisonment, which was upheld by both the Sessions Court and High Court in appeal.

The Supreme Court, while hearing the appeal, considered the arguments of Dr. Manish Singhvi, learned senior counsel for the appellant, who contended that “the said unfortunate incident is admittedly a case of road accident without any malicious intent on the part of the appellant and that no constructive purpose shall be served by making the appellant go through the incarceration period.” The counsel suggested that instead of imprisonment, the appellant could be granted the benefit of probation under the Probation of Offenders Act, 1958 or Section 360 of CrPC, along with payment of compensation to the victim’s family.

Read also: https://judgmentlibrary.com/supreme-court-upholds-compensation-award-in-fatal-road-accident-case-key-legal-analysis/

The Court took a compassionate view of the matter, noting that “Considering the facts and circumstances of the case, we find no reason to interfere with the concurrent conviction against the appellant. However, with regard to the sentence imposed, we deem it appropriate to extend to the appellant the benefit under the Probation of Offenders Act and set aside the sentence by which he has been directed to undergo simple imprisonment for six months.”

In a significant humanitarian gesture, the Court directed the appellant to pay Rs 10 lakh as compensation to be distributed equally among the ten surviving legal heirs of the deceased, most of whom were agricultural workers or daily-wage labourers. The judgment details the family circumstances: “since it is apparent that the legal heirs of the deceased are mostly agricultural workers or daily-wage labourers belonging to underprivileged sections of the society, we believe that it will be beneficial if some assistance is extended to the legal heirs by the District Legal Services Authority in receiving & disbursing the said amount.”

The Court issued specific directions for implementation: “the appellant is directed to deposit a sum of Rs. 10,00,000/- (Rupees ten lakhs only) with the Trial Court within eight weeks from today. Out of the said amount, Rs. 1,00,000/- (Rupees one lakh) is to be paid to each of the ten legal heirs of the deceased.” Additionally, the District Legal Services Authority was tasked with assisting the family members in opening bank accounts and ensuring proper disbursement of the compensation.

This judgment demonstrates the judiciary’s balanced approach in road accident cases – upholding the conviction to maintain deterrence against rash driving, while modifying the sentence to provide meaningful compensation to victims’ families. The Court recognized that financial support would be more beneficial to the impoverished family than the appellant’s incarceration, setting a precedent for similar cases where compensation can serve both punitive and restorative justice purposes.

Read also: https://judgmentlibrary.com/supreme-court-upholds-pay-and-recover-order-in-oil-tanker-accident-case/

Petitioner Name: Sanjay Colaro.
Respondent Name: State of Karnataka.
Judgment By: Justice Vikram Nath, Justice K.V. Viswanathan.
Place Of Incident: Ramadevara Pada, Bengaluru-Mysuru Road.
Judgment Date: 21-04-2025.
Result: allowed.

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