Case Law On High Court And Supreme Court Rulings, Sentencing, And Compensation In Acid Attack Cases

11 Oct 2025 --
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Acid attacks are treated as one of the most heinous crimes against women in India. The courts have consistently emphasized strict punishment and adequate compensation for victims, especially after the insertion of Sections 326A and 326B into the Indian Penal Code (IPC) through the Criminal Law (Amendment) Act, 2013.

Below are five major case laws with detailed explanations of facts, rulings, reasoning, sentencing, and compensation:

1. Laxmi v. Union of India (2014) 4 SCC 427

Court: Supreme Court of India
Bench: Justice R.M. Lodha and Justice Kurian Joseph

Facts:

Laxmi, a young woman, was attacked with acid in 2005 by a man whose marriage proposal she had rejected. She filed a Public Interest Litigation (PIL) seeking stricter laws, regulation of acid sales, and compensation for victims.

Issues:

Lack of regulation on the sale of acid.

Need for rehabilitation and compensation for victims.

Inadequacy of existing penal provisions.

Judgment:

The Supreme Court issued a series of landmark directives:

Regulation of Acid Sale: Acid cannot be sold without a license. Sellers must maintain a log of purchasers, who must provide identification and reasons for purchase.

Minimum Compensation: The Court directed all States and Union Territories to ensure a minimum compensation of ₹3 lakhs to acid attack victims — ₹1 lakh to be paid immediately for medical treatment and the rest for aftercare and rehabilitation.

Free Medical Treatment: All private and government hospitals were directed to provide free treatment to victims, including reconstructive surgeries and medicines.

Amendment of IPC: The Court observed that the punishment for acid attacks was insufficient under the existing law, leading to the eventual insertion of Sections 326A and 326B IPC (2013).

Significance:

This case is foundational — it redefined India’s legal and social response to acid attacks, focusing not just on punishment but also on prevention and rehabilitation.

2. Parivartan Kendra v. Union of India (2016) 3 SCC 571

Court: Supreme Court of India

Facts:

A Bihar-based NGO, Parivartan Kendra, filed a petition regarding two Dalit sisters who were attacked with acid in 2012. They had not received proper medical aid or compensation as required by the Laxmi judgment.

Issues:

Non-compliance with the Laxmi v. Union of India directions.

The need for a uniform scheme for victim compensation and rehabilitation.

Judgment:

The Supreme Court came down heavily on the Bihar Government:

Directed the State Government to pay ₹10 lakh compensation to each victim.

Ordered immediate medical treatment and reconstructive surgery at government cost.

Reiterated that States must ensure effective enforcement of the Laxmi guidelines.

Significance:

The Court reaffirmed that compensation is a right, not charity. It also emphasized State accountability for non-compliance.

3. State of Rajasthan v. Kailash Chand (2013 SCC OnLine Raj 2289)

Court: Rajasthan High Court

Facts:

The accused threw acid on a young girl who rejected his marriage proposal, causing permanent facial disfigurement.

Trial Court Judgment:

The accused was convicted under Section 307 IPC (attempt to murder) and sentenced to 10 years’ rigorous imprisonment.

High Court Ruling:

The Rajasthan High Court enhanced the punishment to life imprisonment, noting:

The act was premeditated and brutal.

Acid attack causes “lifelong physical and psychological suffering.”

Even if the victim survived, the intention to cause death was clear from the nature of the act.

Compensation:

The Court directed the State to pay ₹5 lakh compensation to the victim.

Significance:

This case shows the judiciary’s zero-tolerance approach — treating acid attacks as attempt to murder when the intention is evident.

4. State of Uttar Pradesh v. Smt. Sangeeta (2018 SCC OnLine All 2465)

Court: Allahabad High Court

Facts:

The victim was attacked with acid by her husband due to a domestic dispute. The trial court had given a reduced sentence.

High Court Judgment:

The Court enhanced the sentence to life imprisonment, observing:

The crime reflected extreme cruelty and misogyny.

Such offenses “destroy the soul of the victim and her identity.”

The object of sentencing in such cases is deterrence as well as reform of social attitudes.

Compensation:

The Court directed the U.P. Victim Compensation Board to provide ₹10 lakh to the victim and ensure free medical treatment and psychological counseling.

Significance:

This case highlights how courts treat domestic acid attacks seriously and link sentencing to the goal of societal deterrence.

5. State of Madhya Pradesh v. Ramesh (2011 (2) MPLJ 103)

Court: Madhya Pradesh High Court

Facts:

The accused threw acid on his former lover after she refused to continue their relationship. The victim suffered 80% burns and partial blindness.

Judgment:

The High Court upheld life imprisonment under Section 307 IPC.
It also increased the compensation ordered by the trial court from ₹50,000 to ₹3 lakhs, directing that the amount be recovered from the accused if the State failed to pay.

Key Observations:

Acid attacks are “a form of gendered violence” that must attract the harshest punishment.

The Court urged the legislature to introduce a special provision — which was later reflected in Sections 326A and 326B IPC.

Significance:

This judgment is pre-2013, but it played a key role in shaping public and judicial awareness that led to statutory reform.

Summary of Legal Principles Established

Principle	Judicial Source	Effect
Acid attacks constitute grievous, gendered violence	Laxmi v. Union of India	Legal recognition and social awareness
Free medical treatment and minimum ₹3 lakh compensation	Laxmi and Parivartan Kendra	Mandatory State obligation
Enhanced punishment (life imprisonment) justified	State of Rajasthan v. Kailash Chand, State of U.P. v. Sangeeta	Deterrence and proportionality
Compensation is a legal right	Parivartan Kendra	Victim-centric justice
Pre-2013 cases influenced statutory change	Ramesh case (MP HC)	Led to introduction of IPC Sections 326A & 326B