SAWAL DAS vs THE STATE OF BIHAR

The Supreme Court reviewed its earlier judgment in Criminal Appeal No. 70 of 1972 concerning the conviction of Sawal Das under Section 302 IPC for the murder of his wife, Chanda Devi. The Court clarified that the High Court had erred in assuming that Sawal Das was sentenced under Section 201 IPC, as the Trial Court had not imposed a separate sentence for that offence. The Court maintained Sawal Das's conviction under Section 302 IPC simpliciter and upheld the life imprisonment sentence, while dismissing the application for leave to appeal against the conviction under Section 201 IPC.