Case Brief: Dhananjoy Chaterjee v. State of West Bengal
Case Brief: Dhananjoy Chatterjee v. State of West Bengal (1994)
🕵️♂️ Case Overview
Incident Date: March 5, 1990
Victim: Hetal Parekh, an 18-year-old schoolgirl residing in Bhowanipore, Kolkata
Accused: Dhananjoy Chatterjee, a security guard employed at 'Anand Apartment
Charges: Rape (Section 376 IPC), Murder (Section 302 IPC), Theft (Section 380 IPC
Trial Court Verdict: Conviction under all charges; sentenced to death for murder, life imprisonment for rape, and five years for theft
Appeals: Conviction upheld by Calcutta High Court; Supreme Court affirmed death sentence on January 11, 1994
⚖️ Legal Issues
Admissibility of Dying Declarations: Whether the statements made by the victim before her death were admissible under Section 32(1) of the Indian Evidence Act
Circumstantial Evidence: Evaluation of the circumstantial evidence linking the accused to the crime
Death Penalty Justification: Application of the "rarest of rare" doctrine in awarding the death penalty
🧾 Court's Findings
Dying Declarations: The victim's statements to her mother and a magistrate were deemed admissible as they were made in a fit state of mind and were consistent
Circumstantial Evidence: The accused was identified as the last person seen with the victim; his fingerprints were found on the victim's wristwatch, which was stolen
Death Penalty Justification: The crime was classified as "rarest of rare," warranting the death penalty due to its brutal nature and violation of the victim's trust
⚰️ Execution and Aftermath
Execution Date: August 14, 2004, at Alipore Central Jail, Kolkata
Significance: Dhananjoy Chatterjee was the last person to be judicially executed in India for a crime involving rape and murder
Public Reaction: The execution sparked debates on the death penalty and its application in India
📌 Precedential Impact
Reinforcement of "Rarest of Rare" Doctrine: The case reinforced the Supreme Court's criteria for awarding the death penalty, emphasizing the gravity of the crime and its impact on society
Use of Dying Declarations: The judgment highlighted the importance of dying declarations as a reliable form of evidence in criminal cases
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