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"12.4. On conjoint reading of the aforesaid provisions,
commission of 'robbery' is sine qua non. The 'dacoity' can be
said to be an exaggerated version of robbery. If five or more
persons conjointly commit or attempt to commit robbery it can
be said to be committing the 'dacoity'. Therefore, the only
difference between the 'robbery' and the 'dacoity' would be the
number of persons involved in conjointly committing or attempt
to commit a 'robbery'. The punishment for 'dacoity' and
'robbery' would be the same except that in the case of 'dacoity'
the punishment can be with imprisonment for life. However, in
the case of 'dacoity with murder' the punishment can be with
death also. However, in a case where the offender uses any
deadly weapon or causes grievous hurt to any person, or
attempts to cause death or grievous hurt to any person the
imprisonment with which such offender shall be punished shall
not be less than seven years. Learned Counsel appearing on
behalf of the appellants have rightly submitted that to bring the
case within Section 397 IPC, the offender who uses any deadly
weapon, or causes grievous hurt to any person shall be liable
for minimum punishment under Section 397 IPC. Section 392
and Section 390 IPC are couched in different words. In
Sections 390, 394, 397 and 398 IPC the word used is
'offender'. Therefore, for the purpose of Sections 390, 391, 392,
393,394, 395, 396, 397, 398 IPC only the offender/person who
committed robbery and/or voluntarily causes hurt or attempt to
commit such robbery and who uses any deadly weapon or
causes grievous hurt to any person, or commits to cause death
or grievous death any person at the time of committing robbery
or dacoity can be punished for the offences under Sections
390, 392, 393, 394, 395 and 397 and 398IPC. For the aforesaid
the accused cannot be convicted on the basis of constructive
liability and only the 'offender' who 'uses any deadly weapon....'
can be punished. However, so far as Section 391 IPC 'dacoity'
and Section 396 IPC - 'dacoity with murder' is concerned an
accused can be convicted on the basis of constructive
liability,however the only requirement would be the involvement
of five or more persons conjointly committing or attempting to
commit a robbery - dacoity/dacoity with murder.