Discuss the role of appellate courts in sentence enhancement, with reference to recent rape-case appeals.

Appellate courts do not review only conviction; they also revisit the quantum of punishment, and may raise it where the trial or High Court sentence appears inadequate. The pending Supreme Court proceedings in the Tejpal case, where Goa seeks enhancement to life imprisonment, illustrate this function [1].

Basis of the appellate power over sentence

• Rape law fixes a band, not a figure: rigorous imprisonment of not less than seven years, extendable to life, under the 2013 amendments to IPC Section 376 [2], a scheme carried forward by the Bharatiya Nyaya Sanhita, 2023 [4]. Appellate courts decide where a case sits within that band.
• The State may appeal against inadequacy of sentence: against the Bombay High Court's 10-year sentence, Goa has sought enhancement to life, and the Supreme Court has issued notice on the accused's cross-appeal (September 2026) [1].
• Appellate orders also govern custody consequences, as with the single-judge direction to surrender preceding the Supreme Court notice [1].

Why the power matters

• Uniformity: in the absence of statutory sentencing guidelines, appellate review is the main device aligning comparable cases.
• Marking gravity: a wide seven-years-to-life range loses meaning if its upper end is never invoked. The Justice Verma Committee (2013) treated life imprisonment as the appropriate maximum for rape, rejecting both the death penalty and chemical castration [3].
• Accountability of powerful accused, particularly in workplace settings [1].

Limits on the power

• Notice is not a verdict; enhancement demands a reasoned finding after hearing the convict.
• Verma stressed proportionality and doubted severity as deterrence [3] — enhancement must rest on case facts, not public sentiment.
• Delay erodes the remedy: a 2013 offence reaching only the notice stage in 2026 strains the Article 21 guarantee of speedy justice [1].

Appellate sentencing thus balances consistency with proportionality, making it central to credible punishment for sexual violence. Codified sentencing guidelines and time-bound hearing of sentence appeals would let courts use the full statutory range confidently, advancing the Verma Committee's vision of swift and proportionate justice [3].