What is the core ruling in Parivartan Kendra v. Union of India?

The Supreme Court held that ₹3,00,000 is a minimum baseline compensation for acid attack victims, and States may grant higher amounts. It also pushed for strict control on acid sales.

Is ₹3,00,000 the maximum limit of compensation?

No. The Court clarified there is no cap. The baseline is ₹3,00,000; authorities can award more based on the victim’s needs and circumstances.

Why did the Court stress enforcement against acid sellers?

To prevent future attacks. The Court sought strict action against unauthorized sellers and accountability of officials for lax oversight.

How does this case relate to Laxmi v. Union of India (2013)?

It reaffirms and strengthens Laxmi’s guidelines by treating them as a floor for compensation and implementation, not a ceiling.

Does compensation depend on exact injury categories?

The Court did not fix rigid injury categories. Relief must be realistic, victim-centric, and adequate for rehabilitation.

Parivartan Kendra v. Union of India and Ors (2015)

Quick Summary

In Parivartan Kendra v. Union of India and Ors (2015), the Supreme Court looked at the real life struggles of acid attack survivors—pain, stigma, and long rehabilitation. The Court treated the Laxmi (2013) guidelines as a minimum floor for compensation: at least ₹3,00,000 to every victim. Importantly, it said States and UTs can grant more. The Court also pushed for strict control of acid sales and demanded accountability from officials. This case places survivor-centric relief at the heart of criminal procedure and victim compensation.

Issues

Is there any cap on compensation for acid attack victims?
How should States/UTs implement Laxmi (2013) guidelines on compensation and acid sale control?

Rules

Laxmi v. Union of India (2013) guidelines form the baseline for compensation—minimum ₹3,00,000 per victim.
No upper cap: States/UTs may award higher compensation considering rehabilitation needs.
Regulatory duty: Authorities must restrict unauthorized acid sale and ensure enforcement.

Facts (Timeline)

Night Attack: Four assailants climbed to the rooftop and poured acid on the elder sister; the younger sister suffered burns on her arm.

Parents Respond: Hearing screams, the parents rushed up; the attackers fled.

Medical Delay: The victims were taken to Patna Medical College & Hospital; doctors arrived only the next morning and care was inadequate.

Investigation Lapses: Police were slow to act; the victim’s statement under CrPC §164 was not recorded even by the time of the writ.

Writ & Relief: Petition filed; Supreme Court considered compensation and systemic accountability.

Case timeline for Parivartan Kendra v Union of India

Arguments

Appellant (Parivartan Kendra)

Compensation must be adequate and prompt; treatment delays and poor investigation worsen harm.
No cap should restrict meaningful rehabilitation support.
Authorities must enforce acid sale controls and be answerable for lapses.

Respondent (Union of India & Ors.)

Guidelines exist post-Laxmi; States are implementing measures.
Compensation flows through victim schemes; processes are underway.
Regulation of acid sale is notified; enforcement continues.

Judgment

The Court reaffirmed that ₹3,00,000 is the minimum compensation for each acid attack victim under the Laxmi framework and made it clear that States/UTs can and should grant more where needed. It ordered strict action against unauthorized acid sellers and accountability for weak enforcement. The aim is twofold: realistic rehabilitation and strong deterrence.

Ratio Decidendi

Baseline, not ceiling: The ₹3,00,000 figure is a floor. Relief must match the victim’s rehabilitation needs.
Enforcement duty: States/UTs must ensure effective control of acid sale and take action against violators and negligent officials.
Victim-centric approach: Compensation supports medical care, surgery, counselling, livelihood, and dignity.

Why It Matters

This case converts policy into practice. By removing any perceived cap and tightening enforcement, it pushes governments to fund real rehabilitation and to prevent future attacks. It also reinforces inclusion of survivors in disability lists, opening doors to welfare schemes and long-term support.

Key Takeaways

₹3,00,000 is minimum, not maximum.
States/UTs must enforce acid sale rules and fix accountability.
Compensation should fund full rehabilitation, not token relief.
Guidelines from Laxmi (2013) are the baseline for all cases.

Mnemonic + 3-Step Hook

Mnemonic: “Floor, More, Enforce” — The Court set a Floor (₹3L), allowed More, and told States to Enforce acid sale rules.

Step 1: Start at the Floor (₹3 lakh).
Step 2: Go More for full rehabilitation.
Step 3: Enforce sale controls & fix responsibility.

IRAC Outline

Issue: Is there a cap on compensation for acid attack victims? How should enforcement work?
Rule: Laxmi (2013) sets ₹3,00,000 as minimum; no cap; strict control of acid sale.
Application: Due to medical delay, poor investigation, and severe harm, compensation must be realistic and higher where needed; authorities must act against illegal sellers.
Conclusion: ₹3,00,000 baseline; States/UTs may grant more; stringent enforcement required.

Glossary

CrPC §164: Provision for recording statements/confessions before a Magistrate.
Baseline Compensation: The minimum amount payable; not the upper limit.
Rehabilitation: Medical, psychological, and livelihood support to restore dignity and independence.

FAQs

It is only a starting point. The Court allows higher amounts based on the survivor’s needs—surgeries, therapy, livelihood support, and long-term care.

State/UT authorities must license sellers, monitor compliance, and act against unauthorized supply. Officials can be held accountable for lax enforcement.

No. The Court avoided rigid categories so that compensation can stay victim-centric and practical.

It nudges authorities to include acid attack survivors in the disability list, improving access to welfare schemes and reservations.

Publication Meta

CASE_TITLE: Parivartan Kendra v. Union of India and Ors (2015)
PRIMARY_KEYWORDS: acid attack compensation, CrPC, Supreme Court of India
SECONDARY_KEYWORDS: Laxmi guidelines, disability inclusion, victim rehabilitation
PUBLISH_DATE: 17-Jan-2024

AUTHOR_NAME: Gulzar Hashmi
LOCATION: India
Slug: parivartan-kendra-v-union-of-india-and-ors-2015
Canonical: https://thelaweasy.com/parivartan-kendra-v-union-of-india-and-ors-2015/

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