ISHAR DAS vs STATE OF PUNJAB

The Supreme Court held that Section 4(1) of the Probation of Offenders Act, 1958, has an overriding effect over the minimum sentence prescribed under Section 16 of the Prevention of Food Adulteration Act, 1954, for offenders below 20 years of age. The Court emphasized that the Probation of Offenders Act should be applied to such individuals, reflecting a modern approach to penology. The appeal was allowed, and the High Court's revision of the sentence was set aside, allowing the appellant to benefit from probation instead of imprisonment.