PHOOL KUMAR vs DELHI ADMINISTRATION

The Supreme Court clarified the interpretation of Sections 397 and 398 of the IPC, holding that for an offence under Section 397, the offender must have used a deadly weapon in a manner that instills terror in the victim's mind. The Court ruled that the mere presence of a deadly weapon by an accomplice does not suffice for imposing Section 397 on another offender who did not use one. The appeal was dismissed, affirming the conviction under Section 397 read with Section 342 IPC, with a minimum sentence of seven years upheld.