Parveen Singla Vs State of Haryana

The present criminal revision petition challenges the judgments dated 06.09.2007 and 15.07.2008, whereby the petitioner was convicted under Sections 468, 471 and 511 IPC and sentenced to undergo simple imprisonment for one year, and his appeal was dismissed.

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Briefly, the prosecution case is that the petitioner impersonated as a doctor and falsely claimed to be associated with the All-India Medical Students Association, New Delhi, to collect donation of Rs.300/- for the treatment of poor patients. Upon suspicion, the complainant lodged the present FIR. During trial, it was proved that no such association existed and that the petitioner was not authorized to collect donations. Relying on the prosecution evidence, the learned Trial Court convicted the petitioner under Sections 468, 471 and 511 IPC and sentenced accordingly. The conviction and sentence awarded were affirmed by the learned Appellate Court, giving rise to the present criminal revision petition.

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SANDEEP KUMAR 2026.07.07 14:32 I attest to the accuracy and integrity of this order/judgment.

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CRR No.1597 of 2008 (O&M)

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Learned counsel for the petitioner submits that, out of the sentence awarded, the petitioner has already undergone 2 months and 22 days of imprisonment and has remained on bail since the suspension of his sentence as granted by this Court. It is further submitted on instructions that, considering the nature of the offence and the fact that the petitioner has no criminal antecedents, while affirming the conviction, the sentence awarded may be reduced to the period already undergone by him, with enhancement of the fine, to meet the ends of justice.

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On the other hand, learned State counsel has filed the custody certificate dated 08.05.2026 and has opposed the prayer made by learned counsel for the petitioner and submits that the petitioner has rightly been convicted based upon the evidence available on record and does not deserve any concession and prays that the present petition be dismissed on merits.

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I have heard the learned counsel for the parties and have gone through the record with their able assistance.

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A bare perusal of the material available on record reveals that FIR No.193 dated 08.05.1999 under Sections 419, 420, 467, 468, and 471 of the IPC was registered against the petitioner at Police Station Sector 5, Panchkula. Upon conclusion of the trial, the petitioner was convicted vide judgment dated 06.09.2007 passed by the learned Judicial Magistrate First Class, Panchkula. Aggrieved by the said judgment of conviction, the petitioner preferred an appeal, which came to be dismissed by the learned Additional Sessions Judge, Panchkula, vide judgment dated 15.07.2008, thereby affirming the conviction and sentence awarded by the Trial Court. Thereafter, the petitioner challenged

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SANDEEP KUMAR 2026.07.07 14:32 I attest to the accuracy and integrity of this order/judgment.

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CRR No.1597 of 2008 (O&M)

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both the aforesaid judgments by filing the present Criminal Revision Petition in the year 2008.

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While considering the petitioner's prayer for reduction of sentence, this Court finds that the considerable lapse of time since the commission of the offence, coupled with the prolonged pendency of the proceedings, is a relevant mitigating circumstance. During this period, the petitioner has not been involved in any other criminal case and has maintained a clean record, indicating his reformation. Moreover, the offences are not so heinous as to disentitle him from the relief sought. Further, as per the custody certificate dated 08.05.2026, the petitioner has already undergone more than two months of the substantive sentence out of the total sentence of one year's simple imprisonment. These factors deserve due weight while determining the alteration of sentence awarded by the trial Court.

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A similar issue came up for consideration before the Hon'ble Supreme Court in Israfil @ Pappu @ Naimuddin Khan Versus State of

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Madhya Pradesh, 2026 INSC 654 , wherein, having regard to the peculiar facts and circumstances of the case, including the long lapse of time and other mitigating factors, the sentence awarded to the accused was reduced. The ratio of the said decision lends support to the course being adopted in the present case. The relevant extract of the said judgment is reproduced hereunder:

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“23. This Court, in catena of cases before it, while maintaining conviction, had exercised its discretion and had reduced the substantive sentence considering long passage of time, absence of criminal antecedents and other mitigating circumstances. For instance,

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SANDEEP KUMAR 2026.07.07 14:32 I attest to the accuracy and integrity of this order/judgment.

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CRR No.1597 of 2008 (O&M)

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in Padum Kumar vs. State of Uttar Pradesh , while maintaining conviction for offences including Sections 467 and 468 of the IPC, this Court reduced the sentence considering the age of the matter, the sentence already undergone and taking into account the peculiar facts and circumstances of the case. The long lapse of time without any material indicating repetition of similar criminal conduct is also a relevant consideration while moulding sentence. The appellant has already undergone the rigours of criminal proceedings for over a decade since 2014.”

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The Hon'ble Supreme Court has also recognized that prolonged criminal litigation is by itself a relevant mitigating circumstance while determining the appropriate sentence. Where an accused has lived for years, or even decades, under the shadow of criminal proceedings, facing the uncertainty of the outcome and the social stigma associated with such prosecution, the said experience constitutes a significant factor that deserves to be taken into account while moulding the sentence. The Hon'ble Supreme Court has further observed that such a principle is particularly applicable in cases involving non-heinous offences, where the ends of justice can be adequately served by adopting a reformative and proportionate approach to sentencing rather than a purely retributive one. In the present case also, the allegations against the petitioner are that he impersonated himself as a doctor for collection of donation of only Rs.300/- for treating the poor patient and same does not amount to heinous offence and can be considered for granting relief as prayed for by the petitioner.

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SANDEEP KUMAR 2026.07.07 14:32 I attest to the accuracy and integrity of this order/judgment.

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CRR No.1597 of 2008 (O&M)

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Given the above discussion, the present criminal revision petition is accordingly partly allowed and the jail sentence as awarded by the Courts below is altered to the extent that the same is reduced to the period already undergone by the petitioner, subject to payment of enhanced fine of Rs.10,000/- instead of Rs.5,000/- to be deposited within a period of two months from today, which shall be remitted to the complainant within a period of three months of it, being deposited after proper receipt and identification.

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Bail bonds/surety bonds furnished by the petitioner stands discharged.

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It is clarified that in case the aforesaid fine amount is not deposited within the stipulated period, the same would result in reviving the jail sentence awarded by the Courts below and the petitioner will have to then undergo the remaining jail sentence.

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The pending miscellaneous application, if any, is also disposed of as such.

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(DEEPAK MANCHANDA) 06.07.2026 JUDGE ‘Sandeep’

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Whether speaking/reasoned: Yes No Whether Reportable: Yes No

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SANDEEP KUMAR 2026.07.07 14:32 I attest to the accuracy and integrity of this order/judgment.

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Parveen Singla v. State of Haryana

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Parveen Singla v. State of Haryana

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