Plea bargaining and induced guilty pleas cannot sustain conviction when fairness and Article 21 are compromised.

A conviction based solely on a guilty plea entered under plea bargaining, without proper evaluation of evidence, was treated as unsustainable because inducing an accused to confess guilt in exchange for leniency was held contrary to public policy, unfair, unreasonable, and violative of Article 21. The High Court erred in relying on that plea without examining the circumstances in which it was made and in enhancing the sentence on that basis. The conviction and sentence were therefore set aside, and the matter was remitted for trial in accordance with law after ignoring the guilty plea.

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Issues: Whether a conviction founded solely on a guilty plea entered as part of plea bargaining could be sustained, and whether the High Court was justified in enhancing the sentence on that basis.

Analysis: The conviction recorded by the Magistrate was not based on evaluation of the prosecution evidence but on a plea of guilty induced by an understanding that the accused would receive a light sentence. Such a procedure was held to be contrary to public policy, unfair, unreasonable, and violative of the guarantee of life and personal liberty under Article 21 of the Constitution of India. A conviction obtained by inducing an accused to confess guilt in return for leniency was treated as unconstitutional and illegal. The High Court erred in proceeding on the plea of guilty without examining the circumstances in which it was entered and in enhancing the sentence on that basis.

Conclusion: The conviction and sentence based on plea bargaining could not be sustained, and the matter had to be sent back for trial in accordance with law after ignoring the guilty plea.

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