Parivartan Kendra vs Union of India (2015) - Case Analysis

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Case Overview

Case Title

Parivartan Kendra vs Union of India

Jurisdiction

Civil Original Jurisdiction

Date of the Judgment

7th December 2015

Bench

Justice C. Nagappan and Justice M.Y. Eqbal

Petitioner

Parivartan Kendra

Respondent

Union of India

Provisions Involved

Section 357A of Criminal Procedure Code

Introduction of Parivartan Kendra vs Union of India (2015)

Parivartan Kendra vs Union of India (2015) is a landmark case which highlighted the failure of the States and Union Territories in implementation of compensation and rehabilitation schemes for acid attack victims despite previous directives by the Supreme Court in the Laxmi vs Union of India case. The Petition was filed by an NGO Parivartan Kendra to examine the inadequacies in medical care, sale of acid and insufficient compensation for the survivors of the acid attack.

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Historical Context and Facts of Parivartan Kendra vs Union of India (2015)

The case at hand revolves around a writ petition filed by an NGO highlighting the plight of acid attack victims and the inadequacy of compensation and medical care under existing laws. The petition involves two Dalit girls from Bihar who were attacked in 2012 and pointed out the failures of the medical system, police response and lack of effective compensation schemes for survivors. The petitioner seeks justice, better rehabilitation and the implementation of stringent policies for acid attack victims. The following are the brief facts of the case of Parivartan Kendra vs Union of India -

Overview of the Case

The writ petition filed under Article 32 of Indian Constitution was brought by a registered NGO in public interest. The petition highlighted the inadequate compensation and lack of proper medical and rehabilitative support for acid attack victims in contravention of the Supreme Court decision in Laxmi v. Union of India (Writ Petition (Crl.) No. 129 of 2006). The petitioner sought for urgent intervention to ensure justice and support for acid attack victims.

Facts of the Case

The petition involves two Dalit girls from Bihar who were attacked by acid on the night of 21st October, 2012. The four assailants attacked the girls when they were sleeping on their rooftop. The elder sister who aspired to become a computer engineer had been previously harassed by the attackers who had made sexual advances and threatened her. On the night of the attack, the assailants poured acid on the girls which caused serious injuries. The assailants fled the crime scene when the girls screamed and their parents rushed to their aid.

Medical Treatment and Challenges

Initially the victims were taken to Patna Medical College and Hospital but the medical care provided was inadequate. The family had to pay for the medicines themselves and despite receiving Rs. 2,42,000 from the Bihar government, the medical expenses exceeded Rs. 5 lakhs by the time of filing the writ petition. The surgeries of the elder sister were delayed and poorly performed which led to a transfer to Safdarjung Hospital in Delhi where she was provided proper treatment.

Delayed Legal Action

The perpetrators were not arrested until November 2012 after significant pressure from social organizations and the media. The Petitioner Parivartan Kendra claimed that contrary to promises made by the police, the statement of the victim under Section 164 of the Criminal Procedure Code was never recorded.

Lack of Legal and Medical Support

The Petitioner in Parivartan Kendra vs Union of India contended that acid remains easily accessible in India and contributes to the persistence of such attacks. The compensation schemes are inadequate and the victims face lifelong medical expenses with each surgery costing up to Rs. 3 lakhs. The Petitioner also highlighted the failure of the State machinery to provide comprehensive medical care, rehabilitation and adequate compensation to the victims of acid attack.

International Comparison

The Petitioner also drew attention to our neighbouring country Bangladesh which enacted a law in 2002 to provide better legal protection and support for acid attack survivors. The Petitioner in Parivartan Kendra vs Union of India argued that laws and policies of India are insufficient in acknowledging the severity of acid attacks or providing proper support to the survivors.

Relief Sought

The Petitioner in Parivartan Kendra vs Union of India sought the following relief -

  • Reimbursement of Rs. 5 lakh to the family of the victim for medical expenses already incurred.
  • Compensation of at least Rs. 10 lakh for the pain and suffering of the survivor.
  • Issuance of a writ of mandamus to the State of Bihar to ensure proper treatment and rehabilitation for the victims.
  • Development of standard treatment and management guidelines for acid attack victims including free treatment in private hospitals.
  • Mandatory inclusion of first aid protocols for acid attacks in public health centers, sub-centers and government hospitals.
  • Inclusion of acid attacks under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act.
  • Reforms in school education to raise awareness about the seriousness of violence against women.

Issue addressed in Parivartan Kendra vs Union of India (2015)

The main issue addressed in Parivartan Kendra vs Union of India (2015) was the inadequate enactment of the compensation scheme for the victims of acid attack. Despite the directions issued by the Supreme Court in Laxmi vs Union of India (2014) which set a minimum compensation amount of Rs. 3,00,000, many States and Union Territories failed to provide timely and sufficient compensation. In addition, there were significant loopholes in medical and rehabilitation support for the victims of acid attack. The case also addressed the lack of enforcement of free medical treatment for acid attack victims and the ongoing sale of acid over the counter in certain areas.

Legal Provisions involved in Parivartan Kendra vs Union of India (2015)

Section 357A of the Criminal Procedure Code played a significant role in Parivartan Kendra vs Union of India. The following is the analysis of this provision -

Section 357A of Criminal Procedure Code: Victim Compensation Scheme

Section 357A (Now Section 396 of Bharatiya Nagarik Suraksha Sanhita, 2023) was inserted by the Code of Criminal Procedure (Amendment) Act, 2008 which deals with the victim compensation scheme. It directs the State Government in coordination with the Central Government to prepare a scheme for compensating victims or their dependents who suffer due to crimes and require rehabilitation. The District or State Legal Services Authority decides the quantum of compensation based on the recommendations of the court. If compensation is inadequate or in case of acquittal or discharge additional compensation may be recommended. If the offender is not identified, victims or the family of the victim can apply for compensation. Authorities must complete the inquiry within two months and provide immediate relief like medical aid if necessary.

Judgment and Impact of Parivartan Kendra vs Union of India (2015)

The Supreme Court in the case of Parivartan Kendra vs Union of India dealt with the implementation of compensation for acid attack victims and highlighted that despite earlier directions in the case of Laxmi vs Union of India (2014) some States and Union Territories had not fixed the minimum compensation of Rs. 3,00,000/- per victim. 

The Court underlined that this compensation amount should be made available to all the victims of acid attack and it should not be an undue financial burden on the State Governments or the Union Territories. The Court in Parivartan Kendra vs Union of India also issued directives that private hospitals should provide free medical treatment to acid attack victims and any refusal will result in action under Section 357C of the Code of Criminal Procedure, 1973.

The Court observed that some States had already issued a notification regarding the ban on the sale of acid. The Court in Parivartan Kendra vs Union of India acknowledged the establishment of a Criminal Injuries Compensation Board and accepted the view that the existing District Legal Services Authority can serve as the body responsible for the process of compensation claims.

The Court also noted that several States had failed to enact Victim Compensation Schemes (VSC) and provided minimal compensation ranging from Rs. 25,000 to Rs. 2 lakhs for medical care with many States offering no compensation for rehabilitation. The Court in Parivartan Kendra vs Union of India ruled it necessary to enhance the compensation amount and noted that the minimum Rs. 3 lakh amount prescribed earlier was insufficient given the lifelong treatment needs of the victims of acid attack.

The Court also highlighted that the injuries of the victims caused significant physical and emotional trauma and that they would face difficulties in leading a normal life including challenges related to employment, social stigma and marriage prospects. In view of the gravity of the injuries and ongoing medical needs the Court considered that the victim in the case of Parivartan Kendra vs Union of India, Chanchal deserved compensation beyond the minimum amount. 

The Court noted that her father had already spent over Rs. 5 lakhs on her treatment. After considering the gravity of injury, mental and physical pain and the lifelong impact on the life of the victim the Court awarded Chanchal Rs. 10 lakhs and Sonam who was the elder sister of the victim was awarded the prescribed Rs. 3 lakhs in Parivartan Kendra vs Union of India. The Court directed that Rs. 5 lakhs of the total Rs. 13 lakhs should be paid within one month with the remaining amount to be paid within three months.

The Supreme Court in Parivartan Kendra vs Union of India also directed the State to take full responsibility for the treatment and rehabilitation of the victims in accordance with the guidelines set out in the Laxmi case.

Conclusion

In Parivartan Kendra vs Union of India (2015) the Supreme Court emphasized the necessity for better support for the victims of acid attack including higher compensation, free medical treatment and their rehabilitation. The Court bolstered the previous guidelines issued in Laxmi vs Union of India and mandated that the States must take stringent action to ensure these victims receive proper care and protection.

FAQs about Parivartan Kendra vs Union of India (2015)
  • What was the main issue addressed in the case of Parivartan Kendra vs Union of India?

The inadequate enactment of the compensation scheme for the victims of acid attack, lack of enforcement of free medical treatment for acid attack victims and the ongoing sale of acid.

  • What legal provisions were involved in the case of Parivartan Kendra vs Union of India?

Section 357A of the Criminal Procedure Code played a significant role.

  • What was the decision of the Supreme Court in Parivartan Kendra vs Union of India?

The Supreme Court reinforced the earlier directives issued in Laxmi vs Union of India and mandated that the States must take stringent action to ensure these victims receive proper care and protection.

More Articles for Landmark Judgements

FAQs about Parivartan Kendra vs Union of India (2015)

The inadequate enactment of the compensation scheme for the victims of acid attack, lack of enforcement of free medical treatment for acid attack victims and the ongoing sale of acid.

Section 357A of the Criminal Procedure Code played a significant role.

The Supreme Court reinforced the earlier directives issued in Laxmi vs Union of India and mandated that the States must take stringent action to ensure these victims receive proper care and protection.

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