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Supreme Court of India 2019-10-22 partly_allowed

THE STATE OF MADHYA PRADESH vs UDHAM

Bench: 3 — N.V. Ramana, Mohan M. Shantanagoudar, Ajay Rastogi

In Brief

The State of Madhya Pradesh appealed against a High Court order that reduced the sentences of four accused from three years to the time already served in jail (four days) for an acid attack conviction under IPC Sections 326, 34, and 452. The Supreme Court held that courts must apply three sentencing tests—crime test, criminal test, and comparative proportionality—with detailed reasoning. While acknowledging first-time offenders and trivial motivation as mitigating factors, the Court found the High Court's minimal sentence unjustified given the severity of the violent attack with weapons injuring multiple victims. The Court partly allowed the appeal, enhancing sentences to three months' rigorous imprisonment with substantial fines.

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