In Brief
The Supreme Court examined whether a criminal appeal abates entirely when an appellant dies pending appeal, where the original sentence was composite (imprisonment and fine). The Court held that under Section 394 of the Code of Criminal Procedure, 1973, an appeal against a composite sentence does not abate on the appellant's death because it constitutes an appeal from a sentence of fine, which is expressly excepted from abatement. The sentence of fine affects the deceased's property held by legal heirs. The Court set aside the High Court's judgment and revived the appeal, directing that legal heirs be given a proper opportunity to argue against the fine sentence before the High Court.
The lawyer headnote and full judgment text are available to registered users.