Case Law On Supreme Court And High Court Rulings, Sentencing, And Victim Compensation In Acid Attack Cases
⚖️ 1. Laxmi v. Union of India (2014) 4 SCC 427
Court: Supreme Court of India
Bench: Justice R.M. Lodha and Justice F.M.I. Kalifulla
Facts:
Laxmi, a young woman, was attacked with acid in 2005 by a man whose marriage proposal she had rejected. She filed a PIL before the Supreme Court seeking stricter regulation of acid sales and better compensation and rehabilitation measures for victims.
Judgment:
The Supreme Court issued comprehensive guidelines to prevent acid attacks and to ensure the rehabilitation and compensation of victims.
Key Directions:
Regulation of Sale: The Court directed all States and Union Territories to regulate the sale of acid. Retailers must sell acid only to adults with valid ID proof and reasons for purchase.
Compensation: The Court directed that the minimum compensation to acid attack victims should be ₹3 lakh, under Section 357A CrPC—₹1 lakh for immediate medical treatment and ₹2 lakh for rehabilitation.
Medical Treatment: Hospitals, both private and government, must provide free medical treatment, including reconstructive surgeries.
Criminal Liability: Emphasized the severity of punishment under Section 326A IPC (minimum 10 years, extendable to life).
Significance:
This case became the foundation of acid attack victim rights and inspired amendments in the IPC and CrPC.
⚖️ 2. Parivartan Kendra v. Union of India (2016) 3 SCC 571
Court: Supreme Court of India
Bench: Justice M.Y. Eqbal and Justice C. Nagappan
Facts:
Two Dalit sisters in Bihar were attacked with acid in 2012. They were denied adequate medical care and compensation from the State authorities. An NGO, Parivartan Kendra, filed a writ petition on their behalf.
Judgment:
The Supreme Court strongly criticized the Bihar Government for its negligence and directed ₹10 lakh compensation to each victim.
Key Observations:
The state’s duty to protect victims and provide immediate, adequate compensation was reaffirmed.
Directed that victims must be provided free medical care, psychiatric counseling, and employment support.
The Court emphasized that acid attack victims must not be treated as charity cases but as citizens entitled to full dignity and rights.
Significance:
This case expanded the scope of victim rehabilitation, reinforcing the State’s responsibility and making compensation a right, not a favor.
⚖️ 3. State of Rajasthan v. Parthu (2017 SCC OnLine Raj 1393)
Court: Rajasthan High Court
Facts:
The accused threw acid on a young woman after she refused his proposal, causing severe burns and disfigurement.
Judgment:
The High Court upheld the conviction under Section 326A IPC and enhanced the sentence to life imprisonment, emphasizing the brutality of acid attacks.
Key Observations:
Acid attacks are heinous crimes that leave permanent scars—physical, emotional, and social.
The accused’s motive (revenge for rejection) showed extreme mental depravity.
The Court directed the State to ensure compensation of ₹5 lakh to the victim and free reconstructive surgeries.
Significance:
This case reflected the judiciary’s zero tolerance approach and the trend toward life imprisonment in particularly brutal acid attack cases.
⚖️ 4. Devanand v. State (NCT of Delhi) (2018 SCC OnLine Del 10481)
Court: Delhi High Court
Facts:
The accused threw acid on his estranged wife, causing severe facial and bodily disfigurement. He was convicted under Section 326A IPC and sentenced to 10 years imprisonment.
Judgment:
The Delhi High Court upheld the conviction and emphasized that minimum punishment should not be reduced considering the gravity of such offences.
Key Observations:
Acid attacks are a form of gender-based violence and social terrorism.
Victims often face lifelong trauma; therefore, the law must reflect societal condemnation.
The Court directed Delhi Legal Services Authority (DLSA) to pay ₹8 lakh compensation under the Delhi Victim Compensation Scheme.
Significance:
It reinforced the principle that leniency in sentencing in acid attack cases undermines justice and deterrence.
⚖️ 5. Shabnam v. State of Uttar Pradesh (Allahabad High Court, 2015 SCC OnLine All 6673)
Court: Allahabad High Court
Facts:
A young woman was attacked with acid by her husband and in-laws. The trial court convicted the accused but granted lesser punishment. The victim sought enhancement and compensation.
Judgment:
The High Court enhanced the punishment to life imprisonment under Section 326A IPC and awarded ₹10 lakh compensation to the victim.
Key Observations:
Acid attacks are not only against the individual but against the entire society.
Courts must ensure swift justice and rehabilitative support for victims.
Recognized the psychological damage as part of “grievous hurt.”
Significance:
It marked one of the earliest applications of Section 326A IPC with life imprisonment and maximum compensation in Uttar Pradesh.
⚖️ 6. Kanchan Bala v. State of Haryana (Punjab & Haryana High Court, 2019 SCC OnLine P&H 4210)
Court: Punjab & Haryana High Court
Facts:
The accused threw acid on a woman over a property dispute, causing disfigurement. The trial court awarded 7 years’ imprisonment.
Judgment:
The High Court enhanced the sentence to life imprisonment and directed ₹7 lakh compensation to the victim.
Key Observations:
The minimum sentence under Section 326A IPC should not be the rule but the floor; serious cases require maximum punishment.
The right to live with dignity (Article 21) includes the right to rehabilitation and compensation.
Significance:
The Court reaffirmed that justice for acid attack victims involves not just punishment but also restoration of dignity and livelihood.
🧾 Summary of Legal Principles Across These Cases:
| Legal Aspect | Judicial Position |
|---|---|
| Punishment (Sec. 326A IPC) | Minimum 10 years to life imprisonment; courts favor enhanced sentencing for deterrence. |
| Compensation (Sec. 357A CrPC) | Victims entitled to minimum ₹3 lakh, often increased by courts to ₹5–10 lakh or more. |
| Medical Care | Free treatment, including reconstructive surgery, mandated in both government and private hospitals. |
| Regulation of Acid Sale | Sale restricted to adults with valid ID; unregulated sale punishable under IPC. |
| Rehabilitation | Includes psychological counseling, employment support, and social reintegration. |
🏁 Conclusion
Through these rulings, the Supreme Court and various High Courts have ensured that acid attack cases are treated as crimes of extreme gravity, deserving of severe punishment and comprehensive victim rehabilitation. The judiciary has consistently reinforced that justice is incomplete without both retribution and restitution — punishing the offender and restoring the victim’s dignity.
RELATED Blog
0 comments