SURAJ SINGH GUJAR & ANR. versus THE STATE OF MADHYA PRADESH & ORS.

SURAJ SINGH GUJAR & ANR. versus THE STATE OF MADHYA PRADESH & ORS.

Given the parties are close relatives, the appellants tendered an unconditional apology and executed a compromise deed settling all disputes, the incident was of a minor nature and did not have significant societal impact, and having regard to precedents and the exceptional nature of relief, this Court exercised its extraordinary power under Article 142 of the Constitution to set aside the convictions of the appellants.

Parties
Appellants: Suraj Singh Gujar & Anr.; Respondents: The State of Madhya Pradesh & Ors.
Jurisdiction
India
Judgment Date
30 August 2024
Procedural Posture
Criminal Appeal / Appeal to the Supreme Court Against Conviction and Sentence Affirmed by the Madhya Pradesh High Court (crla No. 1999 of 2013); Leave Granted by This Court
Outcome
Appeal disposed of; convictions of the appellants set aside under Article 142 of the Constitution of India.
Legal Topics
Section 323 of Penal Code, 1860, Section 324 of Penal Code, Section 325 of Penal Code, Compounding of Offences, Non Compoundable Offence, Article 142 of the Constitution, Settlement/compromise Between Parties, Section 482 Cr PC, Section 320 Cr PC, Incident Between Relatives, Nature of Injuries
Criminal Law Constitutional Law Section 323 of Penal Code, 1860 Section 324 of Penal Code, 1860 Section 325 of Penal Code, 1860 Compounding of Offences Non Compoundable Offence Article 142 of the Constitution +5 more

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Parties

Suraj Singh Gujar & Anr.

Appellants

The State of Madhya Pradesh & Ors.

Respondents

Procedural Posture

Criminal Appeal / Appeal to the Supreme Court Against Conviction and Sentence Affirmed by the Madhya Pradesh High Court (crla No. 1999 of 2013); Leave Granted by This Court

Legal Issues

  1. 1 Whether conviction under Section 324 IPC (a non-compoundable offence) can be set aside in light of a compromise between the parties
  2. 2 Whether the Supreme Court may invoke its powers under Article 142 of the Constitution to set aside convictions for non-compoundable offences in exceptional cases
  3. 3 Whether the facts (relationship between parties, nature of injuries, voluntary compromise) justify exercise of Article 142 powers in this case

Ratio Decidendi

Given the parties are close relatives, the appellants tendered an unconditional apology and executed a compromise deed settling all disputes, the incident was of a minor nature and did not have significant societal impact, and having regard to precedents and the exceptional nature of relief, this Court exercised its extraordinary power under Article 142 of the Constitution to set aside the convictions of the appellants.

Court Disposition

Appeal disposed of; convictions of the appellants set aside under Article 142 of the Constitution of India.

Orders

  • Convictions of the appellants set aside by invoking Article 142 of the Constitution.
  • Appellants, who are already outside jail, need not surrender.