📖 Sunita Devi v. State of Bihar, 2024 INSC 448 (decided 17 May 2024)

Facts: A POCSO trial had been concluded in a single day and a death sentence imposed shortly afterwards. The High Court set aside the conviction and sentence for violation of procedural safeguards and ordered a retrial.

Issue: Beyond the procedural defects, how should sentencing discretion be structured?

Held: M.M. Sundresh and S.V.N. Bhatti, JJ. affirmed the order and observed that sentencing cannot be judge-centric: judges do not have unbridled discretion to sentence according to personal notions, and society must know the basis of a sentence. The Court urged the Union Government to consider a comprehensive sentencing policy and a Sentencing Commission.

Ratio: Sentencing must be principled, consistent and reasoned.

Exam use: Use in answers on sentencing policy: a structured framework would guide the choice between custody and non-custodial options such as probation.

📖 Ramesh v. State of Rajasthan, 2025 INSC 46 (decided 9 January 2025)

Facts: A clash between two groups of a family on 1 January 1993 led to cross FIRs. The appellant was convicted under Sections 326, 325, 452 and 323 IPC and sentenced to six months' simple imprisonment, of which he had served over four months. In the cross case, the other group had been granted probation after a settlement between the parties.

Issue: Should the appellant, now about seventy, receive the benefit of Section 4?

Held: B.V. Nagarathna and N. Kotiswar Singh, JJ. extended the benefit of Section 4, noting that the cases were cross cases between members of one family, that a settlement had been reached, that the other side had received probation, and that the appellant was elderly, had no previous record and had already served a substantial part of the sentence. The Court also relied on Article 142.

Ratio: Parity between cross cases, settlement, age, clean antecedents and the passage of time can justify probation even after a conviction for grievous hurt.

Exam use: A strong example of individualised factors outweighing the seriousness of the offence label.

📖 Santosh Sahadev Khajnekar v. State of Goa, 2025 INSC 1041 (decided 26 August 2025)

Facts: During a quarrel at a school in February 2013, the appellant struck a child with a school bag. He was convicted under Sections 323, 352 and 504 IPC and Section 8(2) of the Goa Children's Act, 2003.

Issue: Did a single blow amount to child abuse, and what sentence was appropriate?

Held: Sanjay Karol and Sandeep Mehta, JJ. held that a simple blow with a school bag, without evidence of deliberate or sustained maltreatment, does not amount to child abuse, and acquitted him of that offence and of Section 504. Maintaining the convictions under Sections 323 and 352, the Court released him on probation on his furnishing bonds within three months to keep the peace and be of good behaviour for one year.

Ratio: Once the conviction is reduced to a minor, isolated offence, release under Section 4 is the proportionate response.

Exam use: Shows the Supreme Court correcting over-charging and then applying the Act, as in Sarju Prasad (1964).

📖 Milind s/o Ashruba Dhanve v. State of Maharashtra, 2026 INSC 355 (decided 10 April 2026)

Facts: Four appellants were convicted under Sections 323 and 324 read with Section 34 IPC for assaulting a girl and her father. The trial court imposed only fines of ₹500 to ₹2,000, and the High Court affirmed. Two appellants were government employees for whom the conviction carried service consequences.

Issue: Can an offender sentenced only to a fine be released on probation?

Held: J.K. Maheshwari and A.S. Chandurkar, JJ. held that 'release' under the Act includes release from a sentence of fine, since fine is a punishment and Section 4 operates 'instead of sentencing him at once to any punishment'. The three appellants convicted under Section 324 were released under Section 4 on one-year bonds with supervision; the fourth, convicted only under Section 323, was released after admonition under Section 3. The fines were directed to be paid to the victims as compensation.

Ratio: Probation is available even where the only sentence is a fine.

Exam use: Cite for the fine-only point, for the use of Sections 3 and 4 side by side, and for Section 12 as the practical benefit to employees.

📖 Roshan Lal v. State of Haryana, 2026 INSC 524 (decided 22 May 2026)

Facts: The accused assaulted a night watchman with lathis after he intervened in an altercation, causing skull fractures and prolonged hospitalisation. They were convicted of attempt to murder under Section 307 read with Section 34 IPC. One appellant argued that he was not the principal assailant and should receive the benefit of the Probation Act.

Issue: Was the offence attempt to murder, and should probation be granted?

Held: Sanjay Karol and N. Kotiswar Singh, JJ. held that the severity of injury alone does not prove the intention or knowledge needed for Section 307, and altered the conviction to grievous hurt under Section 325 read with Section 34. Rather than grant probation, the Court sentenced the appellants to the period already undergone, with a fine of ₹50,000 each payable to the injured, and six months' simple imprisonment in default.

Ratio: A request for probation is weighed with all the circumstances; the court may instead fashion an individualised sentence combining time served and substantial compensation.

Exam use: A useful contrast with Ramesh and Khajnekar: where the injuries were grave, the Court gave relief through the sentence and compensation rather than through probation.