Landmark Judgments On Death Row Inmate Conditions
1. Bachan Singh v. State of Punjab (1980) – Death Penalty Constitutionality
Facts:
Bachan Singh was convicted of murder. The case reached the Supreme Court to examine whether the death penalty violated Article 21 (Right to Life) of the Constitution.
Judgment Highlights:
The Supreme Court upheld the constitutionality of the death penalty but emphasized that it should be applied only in the "rarest of rare" cases.
The court recognized the importance of considering prison conditions as a mitigating factor during sentencing.
This judgment indirectly highlighted that inhumane or degrading conditions on death row could influence decisions on sentencing.
Significance:
Established the “rarest of rare” principle for death sentences.
Set a precedent for courts to examine both the crime and the prisoner’s treatment in mitigation.
2. Shatrughan Chauhan v. Union of India (2014) – Delay on Death Row
Facts:
Several prisoners challenged their death sentences due to prolonged delays in the execution of death sentences, which caused severe mental agony.
Judgment Highlights:
The Supreme Court held that unreasonable delay in carrying out the death penalty could convert it into a form of torture, violating Article 21.
A delay of over 14 years on death row was considered sufficient to commute death sentences to life imprisonment.
Courts must consider the mental and physical conditions of inmates awaiting execution.
Significance:
Recognized the impact of prolonged incarceration under a death sentence on mental health.
Set guidelines for reasonable timelines in carrying out capital punishment.
3. Triveniben v. State of Gujarat (1989) – Prison Conditions and Health
Facts:
In this case, inmates on death row complained about poor living conditions, lack of medical facilities, and overcrowding in prisons.
Judgment Highlights:
The Supreme Court observed that prisoners retain their fundamental rights under Articles 14, 19, and 21, even on death row.
The Court emphasized the state’s duty to provide adequate food, medical care, sanitation, and humane treatment.
Any violation could be challenged as a constitutional infringement.
Significance:
Strengthened the legal protection of death row inmates’ rights.
Clarified that inhuman treatment in prisons is unconstitutional.
4. Sunil Batra v. Delhi Administration (1978 & 1980) – Solitary Confinement
Facts:
Sunil Batra challenged the use of solitary confinement and harsh treatment in Tihar Jail, which affected both regular and death row prisoners.
Judgment Highlights:
The Supreme Court ruled that solitary confinement for long periods is unconstitutional, violating Article 21.
Prison conditions for all inmates, including those on death row, must maintain human dignity.
Introduced the concept of judicial supervision of prison conditions.
Significance:
Landmark in prison reforms.
Death row inmates cannot be subjected to arbitrary, degrading, or excessive punitive measures.
5. Sher Singh v. State of Punjab (1983) – Humane Treatment
Facts:
Sher Singh, a death row convict, challenged poor living conditions, lack of legal aid, and denial of family visits.
Judgment Highlights:
The court emphasized that the state must provide basic human rights: adequate food, health care, and family access.
Arbitrary suffering of death row inmates is not justified, regardless of the gravity of the crime.
Significance:
Reinforced that execution procedures cannot justify inhumane treatment.
Death row inmates retain fundamental human rights until execution.
✅ Summary of Key Principles from These Cases:
Death penalty should be used only in “rarest of rare” cases (Bachan Singh).
Prolonged delays on death row can amount to inhuman treatment (Shatrughan Chauhan).
Prison authorities must ensure humane conditions, medical care, and mental well-being (Triveniben, Sunil Batra, Sher Singh).
Death row inmates cannot be subjected to arbitrary punishment or solitary confinement beyond humane limits.
RELATED Blog
0 comments