Summary and Analysis of Nagarajan v. State of Tamil Nadu (2025 INSC 802)

Case Details:

• Citation: 2025 INSC 802

• Court: Supreme Court of India

• Bench: Justices B.V. Nagarathna and Satish Chandra Sharma

• Appeals: Criminal Appeal Nos. 2892-2893 of 2025 (Arising out of SLP (Crl.) Nos. 621-622 of 2024)

• Parties:
  Appellant: Nagarajan (Accused)
  Respondent: State of Tamil Nadu

Background:

1. Incident (2003):
   The appellant, a neighbor of the deceased Mariammal, trespassed into her house at night (11.07.2003) and hugged her, attempting to outrage her modesty (Section 354 IPC).
   Mariammal’s mother-in-law intervened, and the appellant fled.
   The next morning, Mariammal and her infant daughter were found dead in a field after consuming poison (oleander seeds).

2. Trial Court (2015):
   Convicted the appellant under Sections 354 (outraging modesty) and 448 (trespass) IPC, sentencing him to 3 years and 1 month imprisonment + fine.
   Acquitted him under Section 306 IPC (abetment of suicide), holding no evidence of instigation.

3. High Court (2021):
   In the appellant’s appeal against conviction, the High Court suo motu exercised revisional powers under Section 401 CrPC.
   Reversed the acquittal under Section 306 IPC, convicting the appellant and enhancing his sentence to 5 years rigorous imprisonment.

Issues Before the Supreme Court:

1. Whether the High Court could suo motu convert an acquittal into conviction (Section 306 IPC) in an appeal filed by the accused.

2. Whether the High Court could enhance the sentence in an appeal filed by the accused, absent any appeal by the State/victim.

Supreme Court’s Judgment:

Key Legal Principles:

1. Right of Appeal (Section 386 CrPC):
   An accused’s appeal is a statutory and constitutional right.
   In an appeal against conviction, the appellate court can:
   Acquit the accused.
   Reduce the sentence.
   But cannot enhance the sentence (per Section 386(b)(iii) CrPC).

2. Revisional Powers (Section 401 CrPC):
   The High Court cannot suo motu revise an acquittal into conviction (sub-section 3).
   Revision cannot be entertained if an appeal was available but not filed by the State/victim (sub-section 4).

3. Doctrine of Reformation in Pejus:
   An appellant must not be worse off after filing an appeal.
   The High Court’s enhancement of sentence in the accused’s appeal violated this principle.

Decision:

• The Supreme Court set aside the High Court’s conviction under Section 306 IPC and restored the Trial Court’s verdict.

• The appellant’s conviction under Sections 354 and 448 IPC was upheld, and he was directed to serve the original sentence.

Significance:

• Clarifies limits on suo motu revisions by High Courts.

• Reinforces accused’s protection against enhanced sentences in their own appeals.

• Affirms finality of acquittals unless challenged by the State/victim.

Disposition:

• Appeals allowed in part.

• Appellant to serve the original sentence under Sections 354/448 IPC.

Conclusion:

This judgment underscores the procedural safeguards for accused persons, ensuring that their right to appeal does not expose them to greater jeopardy. The Supreme Court’s ruling aligns with principles of natural justice and statutory limits on appellate and revisional powers.