Supreme Court: Judicial Compassion Prevails, Death Penalty Commuted to Life Imprisonment in Murder Case

In a major change of events, the court decided to reduce the death punishment to life imprisonment in a murder case. This conclusion demonstrates a detailed grasp of the crime’s circumstances and considers potential mitigating factors. By deciding on life imprisonment, the court promotes rehabilitation and provides the option of redemption for the guilty individual. This ruling also reflects a developing attitude on capital punishment, emphasizing the importance of second chances and the possibility of rehabilitation within the criminal justice system. It indicates a shift toward a more humanitarian and balanced approach to sentencing in situations of major offenses.

The present case of Madan vs State of UP centres on an unfortunate incident that occurred in 2003. The appellants and their associates were allegedly involved in the murder of six people.
The victims were targeted near Rashid’s house and inside Rizwan’s house. Notably, Rashid and Rizwan were the appellants’ political adversaries in the village panchayat elections.
The appellants were found guilty and sentenced to death for the killings. The High Court upheld Madan’s conviction and commuted Sudesh Pal’s sentence to life imprisonment. The appellants challenged their conviction and punishment to the Supreme Court. Their appeals cited a variety of factors, including the questionable presence of eyewitnesses, discrepancies in testimonies, gaps in the inquiry, and a lack of motive. They also sought mitigation of the death sentence based on rehabilitation and mitigating circumstances.

The Hon’ble Bench of Justice B.R Gavi, Justice B.V Nagrathnamma & Justice Prashant Kumar Mishra Held that: “we find that the present case is not a case wherein it can be held that imposition of death penalty is the only alternative. Another reason that weighs with us is that from the evidence of the witnesses, it is clear that the role attributed to all the accused persons has been similar. The evidence of witnesses would show that the role attributed is that all the accused persons including both the appellants herein had fired shots and indiscriminately indulged in the said firing.

 The trial court-imposed capital sentence on appellants Madan and Sudesh Pal. However, insofar as accused Ishwar is concerned, though the evidence against him is on similar lines, he was sentenced to life imprisonment. The High Court, on the basis of the same evidence, though confirmed the death penalty insofar as appellant Madan is concerned, partly allowed the appeal of Sudesh Pal and sentenced him to undergo life imprisonment.

A perusal of the judgment of the High Court would reveal that the only distinction drawn by the High Court between the cases of Sudesh Pal and Madan is the additional factor that Madan was already awarded life imprisonment in another case. As already observed hereinabove, this Court, in the case of Rajendra Pralhadrao Wasnik (supra), has held that past conduct does not necessarily have to be taken into consideration while imposing death penalty. At the cost of repetition, the role attributed in the evidence of the eye witnesses is identical to all the accused.

 In that view of the matter, we find that the High Court was not justified in imposing death penalty on appellant Madan while converting the death penalty imposed upon Sudesh Pal to life imprisonment. If the judgment of the High Court is maintained, it would lead to an anomalous situation. Whereas appellant Sudesh Pal would be entitled for consideration of his case for remission and premature release on completion of a particular number of years in accordance with the relevant rules, appellant Madan will have to face death penalty.

We are of the considered view that the present case would fall in the middle path as laid down in the case of Swamy Shraddananda (2) alias Murali Manohar Mishra (supra), followed by this Court in various judgments. We find that the interest of justice would be met by converting death penalty into life imprisonment i.e. actual imprisonment for a period of 20 years without remission.  In the result, the appeals are disposed.”

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Written by- Namitha Ramesh

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