The appellant attacked his mother-in-law with a billhook, causing grievous injuries. The Trial Court imposed life imprisonment under Section 307 IPC, which was reduced to 12 years RI by the High Court. The Supreme Court held that the Appellate Court cannot exceed the statutory maximum of 10 years under Section 307 IPC if life imprisonment is not imposed. The sentence was further reduced to 7 years RI, considering the circumstances and relationship between the parties.

The Supreme Court held that the Appellate Court cannot impose a sentence higher than the statutory maximum prescribed under Section 307 IPC.
The Court modified the sentence from 12 years RI to 7 years RI under Section 307 IPC, citing the relationship between the parties and the nature of the injuries. The sentences under Sections 498A and 324 IPC were confirmed to run concurrently, as directed by the High Court.

Discussion on the statutory maximum under Section 307 IPC. (Para 5) Appellate Court’s jurisdiction and limitations. (Para 6) Reference to Amit Rana @ Koka v. State of Haryana, emphasizing the statutory limit under Section 307 IPC. (Para 7) Modification of sentence to 7 years RI under Section 307 IPC. (Para 8)

Major Acts:

1. Indian Penal Code, 1860 (IPC) – Sections 307 (Attempt to Murder), 498A (Cruelty by Husband or Relatives), 324 (Voluntarily Causing Hurt), 506(II) (Criminal Intimidation).

2. Code of Criminal Procedure, 1973 (CrPC) – Appellate Jurisdiction.

Facts:
– The appellant, Ganesan, after losing his job abroad, returned to his family and began harassing his wife and children.
– His wife left him and moved in with her mother, who ran a small business.
– Enraged, the appellant attacked his mother-in-law with a billhook, causing grievous injuries. His wife, who tried to intervene, also suffered injuries.
– The appellant was convicted under Sections 498A, 294(b), 307, and 506(II) of the IPC.
– The Trial Court sentenced him to life imprisonment under Section 307 (Attempt to Murder) for the attack on his mother-in-law, and additional sentences under other sections.
– The High Court reduced the life sentence to 12 years Rigorous Imprisonment (RI) under Section 307, acquitted him under Section 506(II), and confirmed the sentences under Sections 498A and 324.

Issues:

1. Whether the Appellate Court (High Court) had the authority to impose a sentence exceeding the statutory maximum under Section 307 IPC when life imprisonment was not imposed.

2. Whether the sentence of 12 years RI under Section 307 IPC was legally permissible.

Submissions/Arguments:
The appellant challenged the quantum of sentence, arguing that the High Court exceeded its jurisdiction by imposing a 12-year RI sentence under Section 307 IPC, which prescribes a maximum of 10 years if life imprisonment is not imposed.
The respondent (State) supported the High Court’s decision, emphasizing the gravity of the crime and the premeditated nature of the attack.

Ratio:
Appellate Court’s Jurisdiction: An Appellate Court, being a “Court of error,” cannot impose a sentence exceeding the maximum prescribed by law. The power of the Appellate Court is limited to correcting errors and cannot go beyond the competence of the Trial Court. (Para 6, 7)
Section 307 IPC: If life imprisonment is not imposed, the maximum sentence under Section 307 IPC is 10 years. The High Court’s imposition of 12 years RI was unsustainable. (Para 5, 7)
Sentence Modification: Considering the circumstances, the relationship between the parties, and the injuries caused, a sentence of 7 years RI under Section 307 IPC was deemed appropriate. (Para 8)

Subjects:
Attempt to Murder – Appellate Jurisdiction – Sentence Modification – Statutory Maximum – Life Imprisonment – Rigorous Imprisonment – Concurrent Sentences.

Remedy Sought:
The appellant sought a reduction in the quantum of sentence imposed by the High Court under Section 307 IPC.

Reinstatement and Back Wages:
N/A (Not applicable in this criminal case).

Question of Law:
Whether the Appellate Court can impose a sentence exceeding the statutory maximum under Section 307 IPC when life imprisonment is not imposed.