Plea bargaining in criminal appeals cannot replace merits-based adjudication; sentence reduction must rest on the record and law.

Compounding of offences is confined to the limits of Section 320 CrPC, and criminal plea bargaining beyond that framework is not recognised. A conviction or reduced sentence based on negotiated terms is inconsistent with the court's duty to determine criminal liability on the evidence, and is treated as contrary to public policy and fair procedure under Article 21. Even where the accused does not challenge conviction, the court must independently examine the record before maintaining or altering sentence; a concession by the accused cannot by itself justify reduction on bargaining terms. The High Court's order was therefore unsustainable and was set aside, with the matter remitted for decision on merits.

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Issues: Whether the High Court could dispose of a criminal appeal on the basis of plea bargaining and maintain a reduced sentence without deciding the appeal on merits.

Analysis: Compounding of offences is permitted only to the extent provided by Section 320 of the Code of Criminal Procedure, 1973. Beyond that statutory framework, negotiated settlement or plea bargaining in criminal cases is not recognised. A conviction or sentence founded on such bargaining is inconsistent with the duty of the court to decide criminal liability on the evidence on record. The practice is also treated as contrary to public policy and incompatible with the requirements of fair procedure under Article 21 of the Constitution of India. Where an accused does not challenge conviction, the court must still satisfy itself on the record before maintaining or altering sentence; a concession by the accused cannot by itself justify reduction of sentence on negotiated terms.

Conclusion: The High Court's order based on plea bargaining could not be sustained and was set aside. The appeals were allowed and the matter was remitted to the High Court for decision on merits in accordance with law.

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