No Death Penalty If Reform Potential Exists
The Supreme Court upheld the conviction of a man for murdering his wife and four minor daughters. However, it commuted his death sentence to life imprisonment without remission. The Court cited his lack of criminal history, good prison conduct, and potential for reform.
Death Sentence is an Exception, Not the Rule
The Court ruled that judges should impose capital punishment only in the “rarest of rare” cases. Even in multiple murder cases, if there is a chance of reform, a lesser sentence is preferred. The Court emphasized that sentencing must consider the convict’s background, motive, and possibility of rehabilitation.
Case Does Not Fall Under “Rarest of Rare” Category
The Bench of Justices Vikram Nath, Sanjay Karol, and Sandeep Mehta found the case did not meet the criteria set in Bachan Singh v. State of Punjab (1980). The death penalty applies only in exceptionally brutal cases where reform is impossible. Judges must consider the offender’s conduct, lack of prior crimes, and reform potential before imposing capital punishment.
Mitigating Factors Led to Commutation
The Court considered reports from the Probation Officer and the Superintendent of District Jail. These suggested the convict could be rehabilitated. The absence of evidence proving he remained a societal threat led to the commutation of his death sentence.
Precedents Support Commutation
The Court referenced State of Uttar Pradesh v. Krishna Master & Ors. (2010) and Prakash Dhawal Khairnar (Patil) v. State of Maharashtra (2002). In both cases, despite multiple murders, the Court commuted the death sentence to life imprisonment due to reform potential.
Final Judgment By Supreme Court
The Court dismissed the State’s plea for retaining the death sentence. It upheld the conviction but reduced the sentence to life imprisonment without remission, following the principles in Swamy Shraddananda v. State of Karnataka (2008).
