The Supreme Court of India expressed that it was “thoroughly disappointed” with the Madhya Pradesh High Court for rejecting a bail plea without recording reasons. The top court suspended the seven-year sentence, saying High Courts must follow settled law and pass reasoned orders, especially in fixed-term sentence cases.
The Supreme Court of India has suspended the seven-year jail sentence of a man convicted in a counterfeit currency case, strongly criticising the Madhya Pradesh High Court for rejecting his plea for suspension of sentence without giving any proper reasons or following settled legal principles.
A Bench of Justices JB Pardiwala and KV Viswanathan expressed serious dissatisfaction with the High Court’s approach and said that the January 29, 2025 order showed complete non-application of mind.
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The top court observed that the High Court failed to explain what factors influenced its decision and ignored binding judgments governing suspension of sentence in cases involving fixed-term imprisonment.
“We are thoroughly disappointed with the impugned order passed by the High Court,”
the Bench said.
“First, the impugned order could be said to be a non-speaking order. The plain reading of any order should reflect what exactly weighed with the court in passing such order. Secondly, the High Court has failed to apply the settled principles of law while considering the plea for suspension of the substantive order of sentence of a fixed term passed by the trial court.”
The case relates to Sukhchain, who was tried by a Sessions Court in Jabalpur for offences under Sections 489A and 489D of the Indian Penal Code, which deal with counterfeiting currency notes and possession of forged currency.
In September 2024, the trial court convicted him and awarded rigorous imprisonment of seven years on each count, along with a fine of Rs 100.
After challenging his conviction, Sukhchain filed an appeal before the Madhya Pradesh High Court. While the appeal was admitted, he also filed an interim application seeking suspension of his sentence and release on bail until the appeal is finally decided.
However, the High Court rejected the application in January 2025, stating that the appellant had failed to show “clear ambiguity or lapses” in the trial court judgment and that no grounds were made out for suspending the sentence.
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Setting aside this order, the Supreme Court stressed that appellate courts must adopt a liberal approach when dealing with suspension of sentence in cases where the punishment is for a fixed term, as opposed to life imprisonment.
The Bench observed,
“There are two types of sentences that the trial court can impose depending on the nature of the offence. Some orders of sentence are for a fixed term, unlike the order of sentence of life imprisonment. The case in hand is one of a fixed term of sentence. The maximum punishment that has been imposed is seven years,”
The apex court referred to the landmark 1999 judgment in Bhagwan Rama Shinde Gosai Vs State of Gujarat and reiterated that when a convicted person has been sentenced to a fixed period of imprisonment and has filed an appeal as a statutory right, suspension of sentence should normally be granted unless there are exceptional circumstances.
The Bench pointed out that the High Court’s order did not even consider this well-settled legal position.
The Supreme Court also criticised the High Court for passing what it described as a “non-speaking order”, even though the appellant had raised several important grounds in support of his plea.
These included alleged inconsistencies in the recovery of currency notes, failure to examine forensic evidence, and doubts regarding the credibility of the seizure process.
Without commenting on the merits of the conviction itself, the apex court held that the High Court was still duty-bound to explain why the case did not deserve suspension of sentence, especially when the appeal had already been admitted.
Emphasising the need for reasoned judicial orders, the Bench remarked,
“The plain reading of any order should reflect what exactly weighed with the court.”
Allowing the appeal, the Supreme Court set aside the High Court’s orders and directed that Sukhchain be released on bail. The Bench clarified that his release would be subject to such terms and conditions as the trial court may consider appropriate.
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