NAGARAJAN VS STATE OF TAMIL NADU
The case is between Nagarajan and State of Tamil Nadu, embodying a critical question of Law, i.e., whether the High Court exercises Suo Motu Revision Power to enhance the Sentence? Whether the High Court has the Power to enhance the Sentence when the same is not prayed for by the State, a complainant or a victim?
The facts of the case were that the deceased person committed suicide, and it was suspected that the Accused had instigated the deceased to commit suicide. For the same, a FIR No. 239/2003 and a charge sheet were filed on 30.10.2003 under Section 306 of the IPC. However, the trial court held that the appellant did not instigate the deceased to commit suicide. Consequently, the Trial Court acquitted the appellant under Section 306 of the IPC. However, the Accused was convicted under Sections 354 and 448 of IPC and sentenced to undergo simple imprisonment for three years and one month and to pay a fine of Rs. 25,000/- and in default whereof to undergo simple imprisonment for three months for the offence under Section 354 of IPC and a further sentence simple imprisonment for three months for the offence under Section 448 of IPC. However, the High Court, upon a prima facie appraisal of the Trial Court’s reasoning, formed the view that the appellant’s acquittal under Section 306 of the IPC may require further examination and had Suo Motu directed the registration of a criminal revision case to examine the propriety of the acquittal.
The Supreme Court of India held that in the absence of any appeal filed by the victim, complainant or the State, the High Court cannot exercise suo motu revision either to enhance the sentence or to convict the appellant on any other charge.
The significance of Nagarajan vs State of Tamil Nadu lies in delineating the boundaries of judicial discretion within the criminal justice system. The Supreme Court’s ruling underscores the fundamental principle that courts must act within the framework of due process and established procedural norms. By holding that the High Court cannot exercise suo motu revision powers to enhance a sentence or alter a conviction in the absence of an appeal by the State, complainant, or victim, the judgment reaffirms the importance of procedural fairness and the accused’s right to finality in adjudication.
https://api.sci.gov.in/supremecourt/2023/46358/46358_2023_3_1504_62151_Judgement_04-Jun-2025.pdf