Alteration of Conviction From Robbery With Hurt to Grievous Hurt Under the Principle of Cognate Offences

sketch of the Supreme Court of India
Case
APPA v. THE STATE OF MAHARASHTRA (Supreme Court of India, 07-10-2026)
Law
Code of Criminal Procedure, Indian Penal Code.

Highlights of the Judgment:

  • Examination of the necessity of a Test Identification Parade when identity is established via a prompt FIR and adequate lighting.
  • Application of Section 222 of the Code of Criminal Procedure regarding conviction for a minor or cognate offence when the major charge fails.
  • Differentiated analysis between robbery with hurt under Section 394 of the IPC and voluntarily causing grievous hurt under Section 325 of the IPC due to lack of property recovery.
  • Judicial precedent on exercising sentencing discretion following prolonged pendency of criminal proceedings.