Featured image for Supreme Court Judgment dated 20-02-2019 in case of petitioner name State of Madhya Pradesh vs Suresh
| |

Supreme Court Restores Three-Year Sentence for Man Convicted of Killing His Father

The case of State of Madhya Pradesh vs. Suresh revolves around the conviction of the respondent for culpable homicide not amounting to murder under Section 304 Part II of the Indian Penal Code (IPC). The Supreme Court examined whether the High Court erred in reducing the sentence below the punishment awarded by the Trial Court.

Background of the Case

The case dates back to May 13, 1996, when the respondent, Suresh, assaulted his father, Tulsiram, with a blunt object. The attack resulted in a skull fracture, and the victim succumbed to his injuries the same night at Betul Hospital. The police initially registered a case under Section 174 Cr.P.C. but later charged Suresh under Sections 201 and 302 IPC after witness statements revealed that he was seen assaulting his father.

During the trial, the prosecution relied on multiple eyewitnesses, including:

  • PW-3, Sawalbai, who saw the respondent hitting his father with a lathi.
  • PW-2, Babulal, who heard cries and found the accused assaulting his father.
  • PW-4, Dinesh alias Mathu, who corroborated the testimonies of the other witnesses.

The accused, however, claimed that his father sustained injuries due to a fall from the roof.

Trial Court’s Findings

The Trial Court found the accused guilty of culpable homicide not amounting to murder under Section 304 Part II IPC. The court held that while the accused knew his actions could cause death, there was no intention to commit murder as defined under Section 300 IPC. The accused was also charged under Section 201 IPC for providing false information about his father’s death, but no separate sentence was imposed for this charge.

The Trial Court sentenced Suresh to three years of rigorous imprisonment.

High Court’s Decision

On appeal, the Madhya Pradesh High Court upheld the conviction but reduced the sentence to the period already undergone, which was three months and 21 days. The High Court justified its decision by noting:

  • The incident happened in the heat of the moment.
  • The accused was 26 years old at the time of the crime.
  • The accused himself took his father to the hospital after the incident.
  • Given the time elapsed since the crime, sending him back to jail served no purpose.

Petitioner’s Arguments

The State of Madhya Pradesh challenged the High Court’s decision, arguing:

  • The High Court unjustifiably reduced the sentence without considering the gravity of the crime.
  • The accused committed a serious offense by killing his own father.
  • The principle of proportionality in sentencing was ignored.
  • The punishment should serve as a deterrent, and reducing it would undermine public confidence in the justice system.

Respondent’s Arguments

The defense contended:

  • The High Court’s sentence was appropriate given the mitigating factors.
  • The accused did not have any prior criminal record.
  • The act was not premeditated and occurred in the heat of the moment.
  • Since the accused had already undergone imprisonment, further jail time was unnecessary.

Supreme Court’s Observations

The Supreme Court analyzed the case based on legal principles and past precedents.

“The High Court has interfered with and reduced the sentence awarded by the Trial Court on rather irrelevant considerations, while ignoring the relevant factors and governing principles for the award of punishment.”

The Court cited the principle of proportionality and emphasized:

“The punishment to be awarded must be commensurate with the gravity of the crime. Leniency in cases involving violent offenses can undermine the justice system.”

The Court referred to previous rulings, such as State of Madhya Pradesh vs. Ghanshyam, where it was held that a lenient approach in sentencing violent crimes can erode public confidence in law enforcement.

Final Judgment

The Supreme Court ruled:

  • The High Court’s reduction of the sentence was unjustified and legally incorrect.
  • The original sentence of three years’ rigorous imprisonment awarded by the Trial Court was restored.
  • The accused must surrender within four weeks to serve the remaining portion of his sentence.

Conclusion

This judgment reinforces the importance of maintaining the principle of proportionality in sentencing. The Supreme Court’s decision ensures that undue leniency is not granted in serious criminal cases, particularly those involving violent offenses against family members. By restoring the original sentence, the Court has upheld the deterrent effect of criminal law and emphasized that justice must be balanced with both mitigating and aggravating circumstances.


Petitioner Name: State of Madhya Pradesh.
Respondent Name: Suresh.
Judgment By: Justice Dinesh Maheshwari.
Place Of Incident: Betul, Madhya Pradesh.
Judgment Date: 20-02-2019.

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

Download Judgment: State of Madhya Prad vs Suresh Supreme Court of India Judgment Dated 20-02-2019.pdf

Direct Downlaod Judgment: Direct downlaod this Judgment

See all petitions in Bail and Anticipatory Bail
See all petitions in Attempt to Murder Cases
See all petitions in Judgment by Dinesh Maheshwari
See all petitions in allowed
See all petitions in Remanded
See all petitions in supreme court of India judgments February 2019
See all petitions in 2019 judgments

See all posts in Criminal Cases Category
See all allowed petitions in Criminal Cases Category
See all Dismissed petitions in Criminal Cases Category
See all partially allowed petitions in Criminal Cases Category

Similar Posts