(2025 Live Law (SC) 592)

Facts

• The appellant was neighbour of the family of minor victim (Age 4 years). It was alleged that appellant induced minor victim to his house, undressed & committed rape on her.

• Appellant was convicted by Special Judge, Warora under POCSO & IPC. He was found guilty under Section 3(a) punishable under Section 4 of POCSO Act & Section 363-A and Section 376 of IPC. He was sentenced with:

• • Rigorous imprisonment for 7 years.
• • Fine of Rs. 2000 (in default rigorous imprisonment of 2 months)

• Aggrieved by conviction, he (accused) preferred appeal (Criminal Appeal No. 30/2015) before High Court. During proceedings before appellate High Court, it was observed that special court overlooked:

• • Section 5(m) & Section 6 of the POCSO Act.
• • Section 376(2)(i) of IPC.

Show cause notice was served regarding enhancement of punishment to Sachin. High Court remitted the case back to Special Court & Further it was provided by Special Court for a new enhanced punishment i.e., Life Imprisonment along with Fine of Rs. 5000 (in default rigorous imprisonment for 6 months).

• Sachin challenged the enhanced judgement in Supreme Court.

Issues

I. Whether the High Court was justified in enhancing the sentence of the appellant in the absence of an appeal or revision filed by the State or the victim under the Criminal Procedure Code?

II. Whether the procedure adopted by the High Court in directing enhancement of the sentence violated the principles of natural justice and due process of law?

III. Whether the Special Court acted within its jurisdiction in enhancing the sentence upon remand from the High Court, despite the lack of a formal appeal for enhancement?

IV. Whether the Supreme Court could invoke its powers under Article 142 of the Constitution to restore the original sentence and order the appellant’s release in the interest of complete justice?

Analysis

• The case of Sachin v. State of Maharashtra (2025) is a significant judgment that underscores the importance of procedural fairness and the limitations on the powers of appellate courts in criminal cases.

• The Supreme Court held that a High Court cannot enhance a convict’s sentence in an appeal filed solely by the convict, unless a separate appeal or revision is filed by the State or the victim seeking such enhancement. This ruling reaffirms the principle that justice must not only be done but must be done in accordance with due process.

• By invoking Article 142 of the Constitution, the Court ensured complete justice by restoring the original sentence, especially considering the appellant had already served more than the imposed term. The judgment serves as a critical reminder of the need for judicial restraint and procedural discipline, even in cases involving grave offenses.

• While the crime involved was extremely serious ‘sexual assault on a minor’ the Court emphasized that the ends of justice cannot justify bypassing established legal procedures.

• This decision strikes a balance between upholding the rights of the accused and maintaining the integrity of the criminal justice system.

Judgement

In its judgment, the Supreme Court of India set aside the enhanced sentence imposed by the Special Court pursuant to the High Court’s directions. The Court held that the High Court had no jurisdiction to enhance the sentence in an appeal filed only by the convict, in the absence of a cross-appeal or revision application filed by the State, the complainant, or the victim under Sections 377 or 378 of the Code of Criminal Procedure (CrPC).

The Supreme Court emphasized that procedural safeguards must be strictly followed, especially in criminal matters involving deprivation of liberty. It noted that allowing appellate courts to enhance sentences without proper procedural channels would be contrary to the principles of natural justice and fair trial, as guaranteed under Article 21 of the Constitution.

Taking into account that the appellant had already served more than eleven years of imprisonment, far exceeding the original sentence of seven years the Court exercised its extraordinary powers under Article 142 of the Constitution to do complete justice. It restored the original sentence awarded by the trial court and ordered the immediate release of the appellant.

Therefore, observations made from the Judgement:

• • Appellate courts cannot enhance sentences Suo motu without a proper legal basis.
• • Natural justice demands that the accused must be given a fair opportunity to contest any proposed enhancement.
• • The use of Article 142 was justified to correct the procedural impropriety and prevent further miscarriage of justice.

Conclusion

The significance of Judicial supervision in sentencing & Supreme Court’s role in correcting and redressing legal injustices, both are highlighted in Case of Sachin v. State of Maharashtra (2025). Therefore, the enhancement of the appellant’s sentence by the Special Court, on the directions of the High Court, was procedurally invalid and legally unsustainable. It was observed that in the absence of a proper appeal or revision by the State, victim, or complainant, the High Court had no jurisdiction to direct an increase in the sentence in an appeal filed solely by the convict. Hence, the Supreme Court reaffirmed the importance of due process, natural justice, and the limits of appellate powers. In order to serve justice, Supreme Court exercising its authority under Article 142 of the Constitution, reinstated the previous sentence (seven year’s rigorous imprisonment), noting that the appellant had already served over eleven years and ordered his immediate release.

This case sets a crucial precedent for ensuring that Judicial discretion in criminal matters is exercised within the bounds of law and procedural fairness ensuring that legal errors don not result in prolonged incarnations.