In which leading case did the Hon'ble Supreme Court hold that the benefit of Section 3 or Section 4 of the Probation of Offenders Act, 1958 is subject to the limitations in these provisions, and that 'may direct' in Section 4 does not mean 'must direct'?
State of Gujarat v V.A. Chouhan (AIR 1983 SC 359)
Phul Singh v. State of Haryana (AIR 1980 SC 249)
Ram Prakash v. State of Himachal Pradesh (AIR 1973 SC 780)
Smt. Devki v. State of Haryana (AIR 1979 SC 1948)
Answer and explanation
In Ram Prakash v. State of Himachal Pradesh (AIR 1973 SC 780), the Supreme Court held that Sections 3 and 4 of the Probation of Offenders Act, 1958 are not mandatory, as they use the word 'may' rather than 'must', meaning courts have discretion in granting probation. In Phul Singh v. State of Haryana (AIR 1980 SC 249), the Court further clarified that Section 4 should neither be applied as undue leniency nor invoked in undeserving cases.