Court holds imposition of fine under Section 304B IPC contrary to statutory provisions and directs trial court adherence; Bail allowed pending appeal with conditions.
In a significant judgment dated August 21, 2026, the Allahabad High Court (Lucknow Bench) granted bail to appellant Laxmi Narayan, who was convicted under Sections 498A, 304B of the Indian Penal Code (IPC), and Sections 3/4 of the Dowry Prohibition Act by the trial court. The appellant had been sentenced to rigorous imprisonment of ten years under Section 304B IPC along with a fine of Rs. 20,000, in addition to sentences and fines under other sections.
The High Court took note of a crucial procedural error made by the Additional District and Sessions Judge at the trial level, wherein a fine was imposed under Section 304B IPC. The Court clarified that the statute under Section 304B IPC does not prescribe any fine as a penalty, and therefore the imposition of such a fine was legally impermissible. Emphasizing strict adherence to statutory provisions while awarding sentences, the Court directed the Senior Registrar to communicate this order to the trial judge for future guidance.
The appellant had been on bail during the trial and was found to have not misused the liberty granted to him. The Court took into consideration the appellant's cooperation and the absence of any criminal history. Furthermore, reference was made to the dying declaration of the deceased, which indicated that the cause of self-immolation was linked to being scolded by a maternal aunt, casting doubt on the complete attribution of guilt to the appellant.
Considering these factors, the Court allowed bail during the pendency of the appeal subject to conditions, including depositing fines imposed under Sections 498A IPC and the Dowry Prohibition Act, while staying the fine imposed under Section 304B IPC. The appellant was also directed to cooperate fully in the expeditious disposal of the appeal and refrain from any criminal activity.
This judgment highlights the judiciary's commitment to ensuring that sentencing strictly conforms to statutory mandates and safeguards the rights of the accused during the appellate process. It also serves as a reminder to trial courts about the importance of judicial accountability and procedural correctness.
Bottom Line:
Bail granted to the appellant during the pendency of the appeal, noting that the fine imposed under Section 304B IPC was contrary to the statutory provisions, as the imposition of fine is not prescribed for the said offence.
Statutory provision(s):
Indian Penal Code, 1860 - Section 304B, Section 498A;
Dowry Prohibition Act - Sections 3 and 4;
Code of Criminal Procedure, 1973 (procedural aspects regarding bail).
Laxmi Narayan v. State of U.P., (Allahabad)(Lucknow) : Law Finder Doc Id # 2972540
