Case Law On Death Penalty And Life Imprisonment
⚖️ 1. Bachan Singh v. State of Punjab (1980)
Citation: AIR 1980 SC 898
Facts:
Bachan Singh was convicted of murder and sentenced to death under the Indian Penal Code (IPC) Section 302.
He challenged the constitutionality of the death penalty, arguing it violated Articles 14, 19, and 21.
Issues:
Whether the death penalty is constitutional under the Indian Constitution.
Whether life imprisonment should be preferred over death in all cases.
Judgment:
The Supreme Court upheld the constitutionality of the death penalty but restricted it to the “rarest of rare” cases.
It introduced the “rarest of rare” doctrine to decide between death penalty and life imprisonment, considering:
Circumstances of the crime
Nature of the crime
Personality of the offender
Impact:
This case remains the cornerstone of death penalty jurisprudence in India.
Courts must now weigh aggravating and mitigating factors before awarding death.
⚖️ 2. Machhi Singh v. State of Punjab (1983)
Citation: AIR 1983 SC 957
Facts:
Machhi Singh was convicted in a series of murders during a train robbery.
The trial court sentenced him to death, which was challenged in the Supreme Court.
Issues:
Whether the crimes committed warranted the death penalty or life imprisonment.
Judgment:
The Supreme Court elaborated the “rarest of rare” doctrine from Bachan Singh:
Death penalty should only be awarded if the alternative of life imprisonment is unquestionably inadequate.
Factors include viciousness, magnitude, and impact on society.
Impact:
Provided guidelines for trial courts in sentencing and reinforced that life imprisonment is the default penalty unless aggravating circumstances exist.
⚖️ 3. Santosh Bari v. State of West Bengal (2012)
Citation: (2012) 10 SCC 618
Facts:
The case involved a brutal gang rape and murder of a young woman.
The trial court imposed the death penalty.
Issues:
Whether the death sentence was justified given the nature of the crime and social outrage.
Judgment:
The Supreme Court confirmed the death sentence, holding that:
Crimes that shock the collective conscience of society fall under the “rarest of rare” category.
The heinousness and premeditation justified death over life imprisonment.
Impact:
Reaffirmed the principle that death penalty is an exception, reserved for extremely aggravated cases.
⚖️ 4. Shankar Kisanrao Khade v. State of Maharashtra (2013)
Citation: (2013) 3 SCC 94
Facts:
Khade was convicted for murder and abduction of a minor girl.
He appealed against the death sentence, claiming mitigating circumstances.
Issues:
Whether the trial court appropriately considered mitigating factors before imposing death.
Judgment:
The Supreme Court commuted the death sentence to life imprisonment, noting:
The offender’s age, mental state, and background were mitigating factors.
Death should only be imposed when aggravating factors vastly outweigh mitigating factors.
Impact:
Reinforced that individual circumstances of the convict are crucial in deciding between death and life imprisonment.
⚖️ 5. Dhananjoy Chatterjee v. State of West Bengal (1994)
Citation: AIR 1994 SC 169
Facts:
Dhananjoy was convicted of murdering a minor girl in a brutal manner.
The trial court sentenced him to death, citing the heinousness of the crime.
Issues:
Whether the crime qualified for the death penalty or life imprisonment.
Judgment:
The Supreme Court upheld the death penalty, stating:
Murder of a minor with extreme brutality constitutes the rarest of rare.
Mitigating factors (like the convict’s background) were outweighed by the nature of the crime.
Impact:
Highlighted that crimes against vulnerable individuals, especially children, may justify the ultimate punishment.
⚖️ 6. Rajendra Prasad v. State of U.P. (1979)
Citation: AIR 1979 SC 916
Facts:
Rajendra Prasad was convicted of murder during a robbery and sentenced to death.
He appealed against the sentence.
Issues:
Whether the death penalty was proportionate for the crime committed.
Judgment:
The Supreme Court commuted the death sentence to life imprisonment, observing:
The crime, though serious, did not shock society to the extent required for death.
Life imprisonment ensures punishment without violating human dignity.
Impact:
Reinforced the principle that life imprisonment can be preferred where death is not absolutely necessary.
⚖️ 7. Mithu v. State of Punjab (1983)
Citation: AIR 1983 SC 473
Facts:
The case involved pre-meditated murder under Section 302 IPC, where death was mandatory.
Issues:
Whether mandatory death sentences violate Article 21 (Right to Life).
Judgment:
The Supreme Court held that mandatory death sentences are unconstitutional, as each case must be judged individually.
Impact:
Strengthened judicial discretion in deciding between death and life imprisonment.
Mandatory death penalty provisions were struck down.
✳️ Conclusion
Death penalty in India is exceptional, applied only in the rarest of rare cases.
Life imprisonment is the default punishment for murder, unless aggravating factors overwhelmingly justify death.
Judicial considerations include:
Nature and gravity of crime
Circumstances of the offender
Societal impact
Possibility of reformation
These cases collectively uphold Article 21 (Right to Life) and prevent arbitrary or disproportionate use of the death penalty.
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