School Bus Driver's Plea to Reduce Six-Month Sentence Rejected; Punjab and Haryana HC Holds Higher Duty of Care on Drivers Carrying Children

The Punjab and Haryana High Court dismissed a criminal revision against conviction under Sections 279, 337 and 338 IPC, refusing sentence reduction to a school bus driver whose reckless driving overturned the bus and injured several children and teachers.

The Punjab and Haryana High Court at Chandigarh, on 31 August 2026, dismissed the criminal revision filed by Manpreet Singh, a school bus driver convicted of rash and negligent driving that caused a bus to overturn near Rest House, Hoshiarpur, injuring school children, teachers, and the bus conductor. Justice Shalini Singh Nagpal, sitting singly, upheld the conviction under Sections 279, 337 and 338 of the Indian Penal Code and refused to reduce the sentence to the period already undergone. The court held that a professional driver entrusted with transporting minor school children carries a duty of care that goes beyond that of an ordinary driver, and that leniency in such cases would not serve the interests of society.

The Accident and the Trial

FIR No. 34 was registered on 23 February 2018 at Police Station City, Hoshiarpur, under Sections 279, 337, 338 and 427 IPC. According to the FIR, on that date at around 4:00 PM, a school bus of Little Flower Model School, Hoshiarpur — bearing registration number PB-07-AL-6954 and driven by Manpreet Singh — came from the direction of the Church at high speed and overturned near Rest House, Hoshiarpur. The bus was carrying school children and staff members, all of whom suffered multiple injuries.

The account was given to police by Ravi Kumar Verma, an e-rickshaw driver who was waiting for passengers near the Indoor Stadium when he witnessed the bus approaching at fast speed, driven recklessly, with the driver failing to apply brakes and losing control on a turn. The injured were taken to Civil Hospital, Hoshiarpur in ambulances and other vehicles.

During investigation, the Investigating Officer visited the spot, prepared a rough site plan, photographed the scene, seized the bus, recorded witness statements under Section 161 Cr.P.C., and arrested the accused who was subsequently released on bail. On completion of investigation, a final report was filed. Copies of the challan were supplied to the accused under Section 207 Cr.P.C.

The prosecution examined fifteen witnesses, including PW-1 Ravi Kumar (the e-rickshaw driver), PW-2 Sania (a Class 10 student travelling in the bus), PW-3 Manjit Kaur (a teacher in the bus), PW-4 Pawan Kumar (the bus conductor), PW-6 Chand Verma (another teacher), and PW-8 Suneha Singh (a student and daily passenger). Three doctors — PW-10 Dr. Upkar Singh Sooch, PW-11 Dr. Rachhpal Singh Bharaj, and PW-12 Dr. Raman Attri — proved the injuries, both simple and grievous, suffered by the bus occupants. The Investigating Officer proved the stages of investigation.

The accused denied the incriminating evidence in his statement under Section 313 Cr.P.C. and pleaded false implication. No defence witness was examined. The learned Judicial Magistrate Ist Class, Hoshiarpur found the prosecution case proved and convicted Manpreet Singh under Sections 279, 337 and 338 IPC, sentencing him to rigorous imprisonment of three months each under Sections 279 and 337 IPC, and six months under Section 338 IPC.

Appellate Court Affirms; Revision Filed Before the High Court

In appeal, the learned Sessions Judge, Hoshiarpur maintained both the conviction and the sentence under all three sections. Dissatisfied, Manpreet Singh filed CRR-1683-2026 before the High Court.

Before the High Court, counsel for the petitioner did not press the challenge to conviction at the threshold. Instead, he confined the prayer to reduction of the substantive sentence of six months to the period already undergone — four months and eight days. The grounds urged were that the accident occurred in 2018 when the petitioner was approximately 25 years old, that he was now 33, that he had no criminal antecedents, and that he was the sole breadwinner of his family.

The State, represented by Additional Advocate General Punjab, opposed the prayer and contended that the sentence was appropriate given the manner of the offence and the injuries caused.

How the Court Appraised the Evidence

Justice Nagpal independently appraised the trial record and found no anomaly, error, or perversity in the appreciation of evidence by either the learned Judicial Magistrate or the Sessions Judge.

PW-1 Ravi Kumar Verma, the e-rickshaw driver, had directly witnessed the bus approaching at high speed and identified Manpreet Singh as the driver. PW-2 Sania, the Class 10 student, identified the driver — whom she saw daily — and gave a precise account of the high speed and the sudden rash turn that caused the bus to overturn. Her right arm was fractured in the accident. PW-3 Manjit Kaur, a teacher who travelled in the bus every day, corroborated the account of PW-1 and PW-2 and suffered injuries to her left shoulder and leg. PW-4 Pawan Kumar, the bus conductor, also attributed rashness and negligence to the accused and suffered a fractured left leg and injuries to his left arm. PW-6 Chand Verma, another teacher, gave an identical account and identified the accused. PW-8 Suneha Singh, a student and daily commuter, supported the same version.

The accused had pleaded a mechanical defect in the bus. That plea was negated by the testimony of PW-15 (renumbered) ASI Amar Nath, who had mechanically examined the vehicle and whose report, Ex. PW-15/A, showed that the bus was in good working condition at the time of the accident.

The court found that the concurrent findings — that the petitioner drove the school bus at high speed within city limits, particularly approaching a sharp turn, rashly and negligently — were not open to interference. The bus turning turtle by itself, in the court's view, reflected rashness, recklessness, and absence of proper care.

Why the Court Refused Sentence Reduction

On the question of sentence, Justice Nagpal laid down the principle that sentencing is not a formality in criminal cases. The court observed that sentencing serves a social purpose and acts as a deterrent, both for the accused and for society, and that the discretion vested in courts must be exercised judiciously, keeping in view the manner of the offence, the age and other circumstances of the accused, the gravity of the offence, and the harm caused to victims.

The court drew a sharp distinction between an ordinary road accident and the facts before it. Manpreet Singh was not a casual driver but a professional driver employed by a school specifically to transport young children and teachers. That employment, the court held, placed a higher duty upon him — to drive safely and responsibly, maintain safe and reasonable speed, keep a proper lookout for turns, maintain vehicle control, and observe all applicable traffic rules and safety regulations. The court stated that he was required to exercise special care and caution to ensure the children reached home safely.

Against that standard, his conduct — driving at high speed within city limits approaching a sharp turn, losing control, and overturning the bus carrying numerous school children — constituted, in the court's assessment, a serious breach of duty in addition to the statutory offences.

The court observed that the sentence of six months awarded by the trial court and affirmed in appeal was “already on the lower side and further reduction in the sentence is not called for.” It held that a lenient view had already been taken by the trial court, and that no further leniency was warranted. The court specifically observed that reduction of sentence in cases of this nature “would not be conducive to the interest of the society at large.”

The personal circumstances urged by the petitioner — age at the time of the offence, absence of prior antecedents, and being the sole breadwinner — were thus held insufficient to warrant modification of the sentence, given the gravity of the breach of duty involved.

Order

Justice Shalini Singh Nagpal dismissed CRR-1683-2026. The conviction and sentence of Manpreet Singh under Sections 279, 337 and 338 IPC, as imposed by the learned Judicial Magistrate Ist Class, Hoshiarpur and affirmed by the Sessions Judge, Hoshiarpur, stand maintained. The prayer for reduction of sentence to the period already undergone was refused. Pending miscellaneous applications, if any, were disposed of.