Supreme Court Restores Three-Year Rigorous Imprisonment in Attempted Murder Case -- High Court's Sentence Modification Set Aside in IPC Sections 307, 326, 324 Case -- Compensation Enhanced to ₹2,00,000 for Victim's Family

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Case Note & Summary

The Supreme Court allowed the appeal challenging the High Court's modification of sentence in a case involving offences under Sections 307, 326 and 324 of the Indian Penal Code, 1860 -- The Private Respondents were convicted for stabbing the victim with knives causing life-threatening injuries -- The Trial Court sentenced them to three years rigorous imprisonment with fine -- The First Appellate Court upheld this sentence -- The High Court modified the sentence to period already undergone (two months) while enhancing the fine -- The Supreme Court held that the High Court's modification was improper as the offence was serious and involved attempt to murder -- The Court restored the three-year rigorous imprisonment sentence and enhanced the compensation to ₹2,00,000 -- The Court emphasized that sentencing must reflect the gravity of the offence and serve as deterrence

Headnote

The Supreme Court allowed the appeal filed by the Appellant challenging the High Court's judgment that modified the sentence of the Private Respondents from three years rigorous imprisonment to the period already undergone (two months) while enhancing the fine -- The Court held that the High Court erred in modifying the sentence as the offence under Section 307 of the Indian Penal Code, 1860 (IPC) was serious and involved stabbing with knives causing life-threatening injuries -- The Supreme Court restored the sentence of three years rigorous imprisonment awarded by the Trial Court and confirmed by the First Appellate Court -- The Court enhanced the compensation payable to the Appellant from ₹1,00,000 to ₹2,00,000 to be paid by the Private Respondents -- The Court emphasized that the object of law is protection of society and deterrence against crime through adequate punishment -- The Court held that compensation cannot be a substitute for appropriate punishment in serious offences like attempt to murder

Issue of Consideration: Whether the High Court was justified in modifying the sentence from three years rigorous imprisonment to the period already undergone (two months) while enhancing the fine, and whether such modification was appropriate considering the gravity of the offence under Section 307 of the Indian Penal Code, 1860

Final Decision

The Supreme Court allowed the appeal -- The Court set aside the High Court's judgment modifying the sentence -- The Court restored the sentence of three years rigorous imprisonment awarded by Trial Court and confirmed by First Appellate Court -- The Court enhanced the compensation payable to Appellant from ₹1,00,000 to ₹2,00,000 to be paid by Private Respondents

2026 LawText (SC) (02) 42

Criminal Appeal No. ................. of 2026 (Arising out of SLP (Criminal) No. 7495 of 2021)

2026-02-17

RAJESH BINDAL J. , VIJAY BISHNOI J.

2026 INSC 164

Mr. A Velan, Mr. M.P. Parthibhan,

Parameshwari

The State of Tamil Nadu & Ors.

Nature of Litigation: Criminal appeal challenging sentence modification by High Court in attempt to murder case

Remedy Sought

Appellant sought restoration of three-year rigorous imprisonment sentence that was modified by High Court to period already undergone

Filing Reason

Appellant challenged High Court's judgment modifying sentence from three years rigorous imprisonment to period already undergone (two months) while enhancing fine

Previous Decisions

Trial Court convicted Private Respondents under Sections 307, 326 and 324 of IPC and sentenced them to three years rigorous imprisonment with fine -- First Appellate Court upheld conviction and sentence -- High Court confirmed conviction but modified sentence to period already undergone (two months) with enhanced fine

Issues

Whether the High Court was justified in modifying the sentence from three years rigorous imprisonment to the period already undergone in a case involving serious offence under Section 307 of IPC Whether compensation can substitute for appropriate punishment in serious offences like attempt to murder

Submissions/Arguments

Private Respondents contended before High Court that more than 10½ years had elapsed since incident and victim had died -- Private Respondents expressed willingness to pay compensation of ₹1,00,000 -- Appellant contended that High Court's sentence modification was improper considering gravity of offence

Ratio Decidendi

The paramount object of law is protection of society and deterrence against crime through adequate punishment -- Sentencing must reflect the gravity of the offence and not be influenced by extraneous considerations -- Compensation cannot substitute for appropriate punishment in serious offences -- The sentencing discretion must be exercised judiciously considering the nature of the offence and its impact on society

Judgment Excerpts

"The supreme objective of law is the protection of society and creating a deterrence against crime by imposing adequate punishment" -- Para 1 "The High Court upheld the conviction of Private Respondents for the offences punishable under Section 307, 326 and 324 of the Indian Penal Code, 1860" -- Para 2 "The High Court confirmed the conviction of the Private Respondents but modified the sentence from rigorous imprisonment for three years to the period of imprisonment already undergone by them, i.e., two months" -- Para 13

Procedural History

Crime registered in 2009 -- Charge sheet filed in 2009 -- Trial Court convicted and sentenced Private Respondents in 2013 -- First Appellate Court upheld conviction and sentence in 2016 -- High Court modified sentence in 2020 -- Supreme Court appeal filed in 2021 -- Supreme Court decided in 2026

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