Teacher Convicted for Assaulting Student: Supreme Court Reduces Sentence

The case of C.R. Kariyappa vs. State of Karnataka revolves around a tragic incident where a school teacher physically assaulted a second-standard student, causing serious injury. The Supreme Court had to decide whether the High Court was correct in overturning the trial court’s acquittal and whether the sentence imposed was appropriate under the law.

Background of the Case

The appellant, C.R. Kariyappa, was a teacher at Rani Chennamma School in Hospet. On an unfortunate day in 1996, he assaulted a student (PW-2) with a wooden stick for not wearing uniform shoes. The assault caused a severe injury to the child’s left eye, resulting in permanent loss of vision.

The child was initially treated at a hospital in Hospet before being referred to M.M. Joshi Hospital in Hubli, where he underwent two surgeries. Despite medical efforts, the student lost sight in his left eye.

The father of the injured child (PW-1) lodged a complaint, leading to legal proceedings against the teacher.

Trial Court’s Verdict

• The Trial Court acquitted the appellant, citing contradictions in the testimonies of key witnesses (PW-3 and PW-4).
• The Court found that PW-2, the injured child, was tutored before testifying and ruled that his testimony alone was insufficient to convict the accused.
• The Trial Court also pointed out that PW-3 and PW-4 were related to PW-1 and therefore lacked independent credibility.
• Additionally, the 25-day delay in lodging the FIR was considered a major flaw in the prosecution’s case.

High Court’s Judgment

• The Karnataka High Court overturned the acquittal and convicted the appellant under Section 326 IPC (voluntarily causing grievous hurt by dangerous weapons or means).
• The High Court sentenced the appellant to two years of imprisonment.
• The conviction was primarily based on the testimony of PW-2 and corroborating medical evidence.

The appellant then approached the Supreme Court.

Arguments by the Petitioner (C.R. Kariyappa)

• The defense argued that the trial court had correctly acquitted the appellant by recognizing the inconsistencies in the prosecution’s case.
• It was contended that PW-2 was tutored and that his testimony should not have been solely relied upon for conviction.
• The 25-day delay in filing the FIR raised doubts about the authenticity of the prosecution’s case.
• Even if the appellant were guilty, the punishment under Section 326 IPC was excessive since the stick used was not a dangerous weapon.

Arguments by the Respondent (State of Karnataka)

• The prosecution maintained that the injury caused to the child was grievous and resulted in the permanent loss of vision, warranting serious punishment.
• PW-3 and PW-4, who were eyewitnesses, consistently testified about the incident.
• The medical evidence clearly established that the child’s eye injury was caused by the appellant’s actions.
• The delay in filing the FIR was explained by the child’s hospitalization and the trauma suffered by his family.

Supreme Court’s Observations

The Supreme Court carefully examined the case and made the following key observations:

• PW-2’s testimony was reliable: The Court ruled that just because a child witness is made aware of courtroom procedures, it does not mean their testimony is unreliable.
• Contradictions in witness statements were minor: The Court found that inconsistencies in PW-3 and PW-4’s statements did not affect their credibility.
• Medical evidence supported the prosecution: The doctors’ testimonies confirmed that the child had sustained severe injuries due to the assault.
• Delay in filing the FIR was not fatal: The Court acknowledged that in cases involving trauma, delays in filing complaints can occur and should not automatically discredit the case.
• Conviction under Section 326 IPC was excessive: The Court noted that the stick used was not proven to be a dangerous weapon, making Section 326 IPC inapplicable.

Key Judgment Excerpts

The Supreme Court ruled:

“The conviction of the appellant under Section 326 IPC is modified to conviction under Section 325 IPC. The sentence of imprisonment is reduced to one year. Additionally, a fine of Rs. 50,000 is imposed. In default, the appellant shall further undergo imprisonment for three months.”

Regarding the issue of tutored testimony, the Court observed:

“When a child witness is examined in court, being unfamiliar with legal procedures, they need to be informed about the importance of truth-telling. This does not amount to tutoring about the incident itself.”

Final Judgment

• The Supreme Court modified the conviction from Section 326 IPC to Section 325 IPC (voluntarily causing grievous hurt).
• The sentence was reduced from two years to one year of imprisonment.
• An additional fine of Rs. 50,000 was imposed, to be paid as compensation to the injured child.
• Failure to pay the fine would result in an additional three months of imprisonment.
• The appellant was directed to surrender within four weeks to serve the remaining sentence.

Conclusion

This judgment highlights the importance of protecting children from corporal punishment in educational institutions. The Supreme Court’s ruling ensures that teachers cannot inflict harm on students without consequences while balancing justice by considering the nature of the weapon used. The ruling also reinforces that procedural delays do not necessarily weaken a genuine case, particularly when the victim is a minor.

Petitioner Name: C.R. Kariyappa.
Respondent Name: State of Karnataka.
Judgment By: Justice R. Banumathi, Justice Indira Banerjee.
Place Of Incident: Hospet, Karnataka.
Judgment Date: 05-09-2018.

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