Modification of sentence to period already undergone upon enhancement of fine for Section 324 IPC conviction.

On October 21, 2022, the appellant allegedly used obscene language against the complainant, Deepak Yadav, in Railway Colony, Satna, and assaulted him on the head with an axe.

The Police Station G.R.P. District Satna registered Crime No. 247/2022 under Sections 294 and 307 of the IPC.

Following the trial in ST No. 33/2023, the 7th Additional Sessions Judge, Satna, convicted the appellant under Section 324 of the IPC (instead of 307) on May 29, 2026, sentencing him to one year of rigorous imprisonment and a fine of ₹5,000.

The appellant challenged this judgment via the present appeal under Section 374 (2) of the Cr.P.C. read with Section 415 of the B.N.S.S., specifically seeking a reduction in sentence rather than contesting the conviction.

1. Whether the conviction of the appellant under Section 324 of the IPC is legally sustainable based on the evidence on record.

2. Whether the appellant’s jail sentence should be reduced to the period already undergone (approximately four months) given the nature of the injuries and his lack of criminal antecedents.

Section 324 of the IPC, which pertains to voluntarily causing hurt by dangerous weapons or means.

Appellate powers under Section 374(2) of the Cr.P.C. regarding appeals from convictions.

The court balanced the punitive nature of the sentence against the mitigating factors, such as the offender being a first-time offender and the injuries being "simple" in nature, to determine the "ends of justice".

The High Court perused the trial record and witness statements, concluding that the Trial Court’s findings were based on a proper appreciation of oral and documentary evidence; thus, the conviction under Section 324 of the IPC was upheld.

The Court noted that the appellant had already served more than four months in jail and took into account several mitigating factors: the injured party's three injuries were classified as "simple"; the appellant is a young individual; he is not a habitual offender; and this was his first offense.

The Court reasoned that since no "fruitful purpose" would be served by re-incarcerating him, a modification of the sentence—substituting further jail time with an enhanced financial penalty—was appropriate.

The jail sentence was reduced to the period already undergone by the appellant (approx. four months). However, the fine was enhanced from ₹5,000 to ₹15,000, to be deposited within two months; the appellant’s bail bond was discharged subject to the payment of the enhanced fine.