Supreme Court Reduces Sentence in Custodial Violence Case While Enhancing Compensation

The Supreme Court of India recently delivered a judgment in the case of Pravat Chandra Mohanty vs. The State of Odisha & Anr., dealing with a custodial violence incident that resulted in the death of a detainee. The case, arising from an incident that took place in 1985, led to the conviction of two police officers under multiple sections of the Indian Penal Code (IPC), including Section 324 (voluntarily causing hurt by dangerous weapons or means) and Section 471 (using as genuine a forged document).

While the Supreme Court upheld the conviction, it reduced the sentence of the accused due to their advanced age and enhanced the compensation awarded to the victim’s legal heirs.

Background of the Case

Incident Leading to the Conviction

On May 4, 1985, Kasinath Naik, the deceased, and the informant, Kusia Naik, visited the Purighat Police Station, Cuttack, Odisha, to respond to a police summons. According to the prosecution, the deceased was brutally assaulted inside the police station by the accused officers, Pravat Chandra Mohanty and Pratap Kumar Choudhury. The assault continued for hours, leading to severe injuries.

The next morning, Kasinath Naik was found dead, and his body bore multiple injuries. The police initially attempted to cover up the incident, filing a fabricated case suggesting that the deceased had been assaulted by unknown persons at a different location. However, subsequent investigations and witness testimonies contradicted this version.

Trial Court Conviction

The Sessions Court convicted both accused under:

Section 304 (Part II) IPC – Causing death by an act done with knowledge that it is likely to cause death.
Section 471 IPC – Using a forged document as genuine.
Section 342 IPC – Wrongful confinement.
Section 323 IPC – Voluntarily causing hurt.

Sentences ranged from five to eight years of rigorous imprisonment.

High Court Appeal

The accused appealed to the Orissa High Court, which, on November 9, 2020, modified the trial court’s judgment:

Conviction under Section 304 (Part II) was set aside.
Conviction under Section 324 IPC was upheld.
Sentence reduced to one year of simple imprisonment.
Compensation of ₹3 lakh awarded to the legal heirs of the deceased.

Supreme Court’s Observations and Judgment

Conviction Upheld

The Supreme Court upheld the conviction under Section 324 IPC, rejecting the argument that the injuries were not serious enough to warrant this charge. The Court ruled:

“The use of wooden lathi and batten, in the manner employed by the accused, is sufficient to sustain a conviction under Section 324 IPC.”

Request for Sentence Reduction

Given that the incident occurred in 1985 and both appellants were above 75 years of age, the defense requested a reduction in their sentence. The Court acknowledged their age but emphasized the gravity of custodial violence:

“Police brutality, especially in a custodial setting, is a crime not only against the individual but against society. Such incidents erode public trust in law enforcement.”

Compounding of Offense Denied

The appellants requested that their offense under Section 324 IPC be compounded. However, the Court denied this plea, citing the public nature of the crime:

“When custodial violence is involved, the offense is not merely against an individual but against society. Such crimes cannot be compromised merely by the consent of the victim’s family.”

Enhanced Compensation for the Victim’s Family

Recognizing the nature of the offense and the suffering of the deceased’s family, the Supreme Court:

Increased the compensation from ₹3 lakh to ₹7 lakh.
Directed that the amount be disbursed among the legal heirs.

Final Sentence Modification

Considering the appellants’ age and time elapsed, the Court reduced the imprisonment term:

Sentence under Section 324 IPC reduced from one year to six months.
Other sentences to run concurrently.

Key Takeaways from the Judgment

Custodial violence is a serious crime and must be punished to uphold public trust.
Compensation is necessary for victims of police brutality.
Age and time elapsed can be factors in reducing imprisonment, but not in erasing guilt.
Forged documents used to cover up crimes can lead to additional legal consequences.

Impact of the Judgment

This ruling reaffirms that custodial violence will not be tolerated and sets a precedent for ensuring accountability in law enforcement. While it recognizes the age and health of convicts, it ensures that justice is served through compensation and proportionate sentencing.

Conclusion

The Supreme Court’s decision in Pravat Chandra Mohanty vs. The State of Odisha strikes a balance between punishment and rehabilitation. It ensures that police brutality is condemned while recognizing human considerations such as age and time elapsed since the crime. By upholding the conviction but reducing the sentence and enhancing compensation, the Court reinforces the principles of justice, accountability, and deterrence.

Petitioner Name: Pravat Chandra Mohanty.
Respondent Name: The State of Odisha & Anr..
Judgment By: Justice Ashok Bhushan, Justice Ajay Rastogi.
Place Of Incident: Cuttack, Odisha.
Judgment Date: 11-02-2021.

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Supreme Court Reduces Sentence in Custodial Violence Case While Enhancing Compensation