Four appellants — government employees — were convicted under ss.323 and 324 r/w s.34, IPC for assaulting members of the same locality during a Diwali-morning altercation in 2019. The Trial Court (Special Judge, POCSO, Beed) and the Bombay High Court (Aurangabad Bench) imposed only fines — Rs.500/- under s.323 and Rs.2000/- under s.324 — with no term of imprisonment. Before the Supreme Court, the appellants abandoned the merits and pressed solely for the benefit of ss.3 and 4 read with s.12 of the Probation of Offenders Act, 1958. The State resisted, arguing that s.4 is premised on sparing an offender from incarceration and that the word "release" in s.4 is inapplicable where no imprisonment has been awarded.
Disposed of — the Court extended the benefit of s.4 to A-1, A-2 and A-3 (convicted under both ss.323 and 324) and the benefit of s.3 to A-4 (convicted under s.323 only). The core reasoning is that "punishment" in the 1958 Act must be read in light of s.53 IPC and s.4 BNS, both of which enumerate fine as a distinct form of punishment alongside imprisonment; ss.3 and 4 of the 1958 Act therefore naturally extend to sentences of fine alone. The word "release" in s.4 cannot be confined to release from physical custody — it must be read as setting the offender at liberty from the obligation to serve any sentence, including payment of fine.
The Court also noted the divergence between Sanjay Dutt (A-117) v. State of Maharashtra (holding that s.360 CrPC and the 1958 Act cannot co-exist) and Lakhanlal v. State of M.P. (holding them mutually co-existent by virtue of s.360(10) CrPC and the non obstante clause in s.4 of the 1958 Act), but declined to resolve that conflict, confining itself to the fine-only question. Relevant factors considered: no prior or subsequent criminal record, government employment, absence of moral turpitude, and the reformative object of the 1958 Act. Fines directed to be treated as compensation to the victims. By virtue of s.12, no service disqualification shall attach to the conviction.