A disturbing case from northern Karnataka, involving the brutal burning of a widowed mother of five, returned to focus at the Supreme Court this week. While the conviction of the accused remained untouched, the court closely examined how far a trial court can go while fixing punishment. Sitting in criminal appellate jurisdiction, the bench stepped in to correct what it felt was a legal overreach in sentencing, even as it acknowledged the sheer cruelty of the crime.
Background
The incident dates back to the night of January 1, 2014. According to the prosecution, the accused, a relative by marriage, had been making repeated sexual advances towards the woman. When she refused, he allegedly poured kerosene over her inside her modest shanty and set her on fire. She survived for ten days, battling 60 per cent burns, before succumbing in hospital.
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The Sessions Court convicted the man for murder under Section 302 of the IPC and imposed life imprisonment “till the end of natural life,” also denying him remission and set-off for time spent in custody. The High Court upheld this. The matter reached the Supreme Court, initially on the narrow issue of whether such a sentence was legally permissible.
Court’s Observations
Although notice was limited to sentencing, the bench, led by Justice K. Vinod Chandran, scanned the record to satisfy itself on guilt, especially since close relatives, including the victim’s daughter, had turned hostile. Neighbours and the victim’s brother-in-law placed the accused at the scene, and crucially, two dying declarations recorded by a police officer and a magistrate consistently blamed him.
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“The conviction, in our view, stands on firm footing,” the bench observed, noting that medical evidence clearly established homicide.
However, the judges drew a clear line on sentencing powers. Referring to earlier rulings like Swamy Shraddananda and the Constitution Bench decision in V. Sriharan, the court explained that while life imprisonment legally means imprisonment for the entire life, the authority to deny remission or create special categories lies only with constitutional courts. “A Sessions Court, being a creation of the CrPC, cannot curtail statutory remission or set-off,” the bench said in substance.
On Section 428 of the CrPC, the court was blunt. Denying set-off for pre-trial custody directly contradicts the law, and such a direction “cannot stand.”
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Decision
In the end, the Supreme Court partly allowed the appeal. The conviction for murder was confirmed. The sentence was modified to simple life imprisonment under Section 302 IPC, without the rider of “till natural life.” The bar on remission and commutation imposed by the trial court was removed, and the accused was held entitled to set-off for time already spent in custody. Other sentences were left untouched and will run concurrently. The court clarified that any future remission would depend on the government’s policy and decision, and nothing more.
Case Title: Kiran vs The State of Karnataka
Case No.: Criminal Appeal arising out of SLP (Crl.) No. 15786 of 2024
Case Type: Criminal Appeal (Murder – Section 302 IPC)
Decision Date: 18 December 2025
