Conviction for Death in Road Accident Is Upheld; Jail Term Converted to Probation with Rs.10 Lakh Compensation Ordered

A bench of Justice Vikram Nath and Justice K.V. Viswanathan heard an appeal against the Karnataka High Court's dismissal of a criminal revision challenging conviction under Sections 279 and 304A, Indian Penal Code, arising from a fatal road accident on Bengaluru–Mysuru Road.

The Court upheld the concurrent findings of guilt but modified the sentence. The judges observed that while there was "no reason to interfere with the concurrent conviction against the appellant," the facts warranted mitigation of punishment and monetary relief to the victim's family. The Court, in its reasoning, observed: "Considering the facts and circumstances of the case, we find no reason to interfere with the concurrent conviction against the appellant. However, with regard to the sentence imposed, we deem it appropriate to extend to the appellant the benefit under the Probation of Offenders Act and set aside the sentence by which he has been directed to undergo simple imprisonment for six months. Further, we award a total compensation of Rs. 10,00,000/- (Rupees ten lakhs only) in favour of the surviving legal heirs of the deceased in lieu of the benefit extended to the appellant and the appellant shall duly conform with the payment of such compensation." The Court directed the appellant to deposit Rs.10,00,000 with the trial court within eight weeks, to be disbursed as Rs.1,00,000 each to the ten identified legal heirs; the District Legal Services Authority, Ramanagara, was asked to assist in account-opening and disbursement, and to file a status report within three months.

Background

The prosecution case was that on 29 March 2008 at about 11 a.m., the accused-appellant drove his car in a rash and negligent manner near Ramadevara Pada on Bengaluru–Mysuru Road and struck one Sri Chaluvappa, who sustained multiple injuries and died before reaching the hospital. The accused faced trial in CC No. 431 of 2008 and was convicted on 21 November 2011 by the Principal Civil Judge & JMFC, Ramanagara, under Sections 279 and 304A IPC and sentenced to six months' simple imprisonment and a fine of Rs.5,000 (with one month additional imprisonment in default). The trial court's conviction was affirmed by the Principal District and Sessions Judge, Ramanagara, on 25 February 2013. The appellant's criminal revision petition before the Karnataka High Court was dismissed by judgment dated 21 November 2022, after which the appellant sought special leave to appeal to this Court (SLP (Crl.) No.3455/2023).

Before this Court, senior counsel for the appellant submitted that the incident was "admittedly a case of road accident without any malicious intent" and urged that incarceration would serve no constructive purpose; counsel sought relief under the Probation of Offenders Act, 1958 or Section 360 CrPC and proposed monetary compensation to the deceased's legal heirs. The State filed an affidavit identifying ten surviving legal heirs and their socioeconomic status. Having heard counsel and perused the record, the Supreme Court declined to disturb the finding of guilt but accepted the mitigation proposal, set aside the jail sentence, extended the benefit of probation, and substituted a compensatory scheme in place of incarceration. The Court further directed administrative assistance through the District Legal Services Authority for verification, bank account facilitation and disbursement, and required a compliance report within three months. The appeal was disposed of in terms of these directions.

Case Details: Case No.: CRIMINAL APPEAL No. ____ of 2025 (Arising from SLP (Crl.) No.3455/2023); Citation: 2025 INSC 686 Case Title: Sanjay Colaro v. State of Karnataka Appearances: For the Petitioner(s): Dr. Manish Singhvi, Senior Counsel For the Respondent(s): V.N. Raghupathy, Counsel for State of Karnataka