Showing posts with label S 364A of IPC. Show all posts
Showing posts with label S 364A of IPC. Show all posts

Tuesday, 20 July 2021

Supreme court: In case of Kidnapping For Ransom, it is Necessary To Prove Threat To Cause Death Or Harm For Conviction

 After noticing the statutory provision of Section

364A and the law laid down by this Court in the above

noted cases, we conclude that the essential

ingredients to convict an accused under Section 364A

which are required to be proved by prosecution are as

follows:-

(i) Kidnapping or abduction of any person or

keeping a person in detention after such

kidnapping or abduction; and

(ii) threatens to cause death or hurt to such

person, or by his conduct gives rise to a

reasonable apprehension that such person may

be put to death or hurt or;

(iii) causes hurt or death to such person in order

to compel the Government or any foreign State

or any Governmental organization or any other

person to do or abstain from doing any act or

to pay a ransom.

34. Thus, after establishing first condition, one

more condition has to be fulfilled since after first

condition, word used is “and”. Thus, in addition to

first condition either condition (ii) or (iii) has to

be proved, failing which conviction under Section

364A cannot be sustained.

35. The second condition which is “and threatens to

cause a death or hurt to such person, or by his

conduct gives rise to a reasonable apprehension that

such person may be put to death or hurt” is relevant

for consideration in this case since appellant has

confined his submission only regarding nonfulfillment

of this condition. 

39. The High Court has not dealt with the grounds

taken before it by the accused that no threat to

cause death or hurt was extended by the accused. From

the judgment of the high court, thus, it can be said

that there is no finding regarding fulfillment of

condition No.2. Both the Courts having not held that

condition No.2 as noted above was found established

on the evidence led before the Court the conviction

under Section 364A become unsustainable. The present

is not a case where applicability of condition No.

(iii), i.e., “or causes hurt or death” is even

claimed. Thus, fulfillment of condition No.(ii) was

necessary for conviction under Section 364A.

REPORTABLE

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPEAL NO.533 OF 2021


SHAIK AHMED  Vs  STATE OF TELANGANA 

Author: ASHOK BHUSHAN,J.

Dated: JUNE 28, 2021.

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Sunday, 17 May 2015

Whether offence of kidnapping for ransom is to be proved in three stages?

The important ingredient of Section 364A is the abduction or kidnapping, as the case may be. Thereafter, a threat to the kidnapped/abducted that if the demand for ransom is not made then the victim is likely to be put to death and in the event death is caused, the offence of Section 364A is complete. There are three stages in this Section, one is the kidnapping or abduction, second is threat of death coupled with the demand of money and lastly when the demand is not made, then causing death. if the three ingredients are available, that will constitute the offence under Section 364A of the Indian Penal Code. 

Supreme Court of India

Vishwanath Gupta vs State Of Uttaranchal on 21 March, 2007
Bench: A.K. Mathur, Lokeshwar Singh Panta
Citation;2007CriLJ2296, JT2007(5)SC48,
 2007N.C.C.603, 2007(5)SCALE114,
 (2007)11SCC633, 
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