Tuesday, 27 September 2022

Bombay HC: Category For Premature Release More Beneficial To Convict Will Apply If Case Falls Under Two Different Categories Within Same Guidelines

Thus Supreme Court has held that in case of convicts the

policy which was prevalent when the conviction takes place will apply and if any other liberal policy prevails on the date of consideration of case for premature release then such policy will apply. The said principle of giving benefit to the convict of beneficial policy certainly applies to the two different policies/guidelines but the same will also apply to the categories in the same policy/guidelines, if case falls under both the categories.

10. The present case is squarely governed by the Guideline no. 4 (c)

as the murder took place as a result of trade union activities. Even if, it

is assumed that the petitioners’ case falls under both the categories

namely category no. 4 (c) and category no. 4 (d) of 2010 Guidelines,then also, it is clear that more beneficial category i.e. category no. 4 (c) will apply to the Petitioners’ case.

IN THE HIGH COURT OF JUDICATURE AT BOMBAY

CRIMINAL APPELLATE JURISDICTION

CRIMINAL WRIT PETITION NO. 4544 OF 2021

Uday Dhaku Sutar Vs The State of Maharashtra & Anr. 

CORAM : REVATI MOHITE DERE &

MADHAV J. JAMDAR, JJ.

DATED : 8 th SEPTEMBER 2022

Order : (Per Madhav J. Jamdar J.)

1. Heard. Rule. Rule is made returnable forthwith with the

consent of the parties and is taken up for final disposal. Learned APP


appearing for the respective Respondents wave notice on behalf of the

said Respondents.

2. The Petitioner in each of the above Petition has challenged

the order dated 09th July, 2021 passed by Home Department

(Government of Maharashtra), by which their respective case by

separate orders has been classified in category no. 3(b) of guidelines

dated 11th May, 1992 and category no. 4(d) of the Guidelines dated

15th March, 2010 and accordingly, both of them have been directed to

be released after completion of 24 years of imprisonment including

remission.

3. Mr. Rupesh Jaiswal, learned counsel appearing for the

Petitioner submitted that, the incident in question has taken place on

account of a rivalry between two trade unions namely Mumbai Labour

Union and Bhartiya Kamgar Sena. He submitted that, the deceased was

a member of the Mumbai Labour Union, whereas, both, the Petitioners

belonged to the Bhartiya Kamgar Sena. Learned counsel relied on the

judgment of the Supreme Court in case of State of Haryana & Ors. Vs.

Jagdish reported in (2010) 4 SCC 216 and the judgment dated 25th

February, 2020 passed by the Nagpur Bench of Bombay High Court in

Criminal Writ Petition No. 40 of 2020. He submitted that, case of

Petitioners falls under the category 4 (c) of the Guidelines dated 15th

March, 2010.

4. On the other hand, Mr. J. P. Yagnik, learned APP submitted

that the Respondents have rightly categorised the Petitioners’ case as

falling under category 4 (d) of the Guidelines dated 15th March, 2010

as murder is committed by more than one person.

5. We have perused the judgment of the Additional Sessions

Judge, Greater Bombay dated 10th August, 2007 passed in Sessions

Case No. 695 of 2004. By the said judgment inter-alia the respective

Petitioners i.e. Uday Dhaku Sutar and Ranjay Laxman Sawant (Accused

No. 1 and 3) alongwith Prakash Yeragi (Accused No. 2) were convicted

for the offences punishable under Section 302 read with 34 of Indian


Penal Code and were sentenced to suffer rigorous imprisonment for

life.

6. A perusal of the judgment shows that, the deceased in the

year 2000 was in the employment of Nanavati Hospital. At that time,

there were two unions in Nanavati Hospital namely, the Bhartiya

Kamgar Sena and the Mumbai Labour Union. The deceased was a

member of the Mumbai Labour Union, whereas, all the accused were

members of the Bhartiya Kamgar Sena. In the year 2000, due to

dispute between these two unions there was quarrel and deceased

caused grievous hurt to the Petitioner−Uday Sutar. In respect of the

said incident, Santacruz Police Station had registered a crime as against

the deceased and he was arrested. On 02nd June, 2004, incident in

question took place when all the Accused belonging to the Bhartiya

Kamgar Sena, all of a sudden assaulted the deceased belonging to the

Mumbai Labour Union. On 04th June, 2004 the deceased succumbed

to his injuries.

7. The above factual position on record clearly shows that,

the incident in question had taken place due to trade union activities.

It is the contention of Adv. Jaiswal that category 4 (c) of Guidelines

dated 15th March, 2010 applies to the present case, whereas, the

contention of the State is that category 4 (d) of said 2010 Guidelines is

applicable. The said 2010 Guidelines are issued under Section 438 of

Criminal Procedure Code, 1973. Both these categories namely 4 (c)

and 4 (d) of 2010 Guidelines are set out hereinbelow :-

Category

no.

Sub

category

CATEGORISATION OF

CRIMES

PERIOD OF

IMPRISONMENT TO

BE UNDERGONE

INCLUDING

REMISSION SUBJECT

TO A MINIMUM OF

14 YEARS OF ACTUAL

IMPRISONMENT

INCLUDING SET OFF

PERIOD.

4 MURDERS FOR

OTHER REASON.

c Murder resulting from

trade union activities

and business rivalry.

22 years

d Murder committed by 24 years

more than one person/

group of persons.

8. The guideline no. 4 (c) is regarding murder resulting from

trade union activities and business rivalry. The factual position on

record clearly shows that the incident in question had taken place due

to trade union activities. The guideline no. 4 (d) which has been

applied by the State of Maharashtra is regarding murder committed by

more than one person/group of persons. It is true, that in the present

case, murder has been committed by three persons, however,

Guideline no. 4 (c) specifically contemplates murder resulting from

trade union activities. The said Guideline does not further prescribe

that the same will apply only if murder has been committed by one

person. What is relevant is murder should have been committed as a

result of trade union activities and therefore, whether murder has been

committed by more than one person/group of persons is totally

irrelevant.

9. In the judgment of the Supreme Court in the case of State

of Haryana and Ors. vs. Jagdish (supra) in paragraph no. 54 it has

been held as follows:

“54. The State authority is under an obligation to at

least exercise its discretion in relation to an honest

expectation perceived by the convict, at the time of his

conviction that his case for premature release would be

considered after serving the sentence, prescribed in the

short-sentencing policy existing on that date. The State

has to exercise its power of remission also keeping in

view any such benefit to be construed liberally in favour

of a convict which may depend upon case to case and for

that purpose, in our opinion, it should relate to a policy

which, in the instant case, was in favour of the

respondent. In case a liberal policy prevails on the date of

consideration of the case of a “lifer” for premature

release, he should be given benefit thereof.”

(Emphasis added)

Thus Supreme Court has held that in case of convicts the

policy which was prevalent when the conviction takes place will apply and if any other liberal policy prevails on the date of consideration of case for premature release then such policy will apply. The said principle of giving benefit to the convict of beneficial policy certainly applies to the two different policies/guidelines but the same will also apply to the categories in the same policy/guidelines, if case falls under both the categories.

10. The present case is squarely governed by the Guideline no. 4 (c)

as the murder took place as a result of trade union activities. Even if, it

is assumed that the petitioners’ case falls under both the categories

namely category no. 4 (c) and category no. 4 (d) of 2010 Guidelines,

then also, it is clear that more beneficial category i.e. category no. 4 (c)

will apply to the Petitioners’ case.

11. In view of the above discussion, we quash and set aside

impugned order dated 09th July, 2021 passed by the Respondent No. 1

vis-a-vis both the Petitioners and direct that case of the Petitioners be

8/9

Arjun 44-WP-4544-2021.doc

classified as falling under category no. 4 (c) of 2010 Guidelines.

12. Rule is made absolute in the above terms and Petitions are

disposed of.

13. All parties to act on an authenticated copy of this order.

MADHAV J. JAMDAR, J. REVATI MOHITE DERE, J.

9/9

Print Page

No comments:

Post a Comment