The Supreme Court has reaffirmed that not every case of multiple murders qualifies as a “rarest of rare” instance warranting the death penalty, particularly when there is potential for reform.
In a significant ruling, a bench of justices Vikram Nath, Sanjay Karol and Sandeep Mehta recently commuted the death sentence of a man convicted of murdering his wife and four minor daughters, sentencing him instead to life imprisonment without remission.
The court underscored that while the crime was brutal and deeply disturbing, the absence of criminal antecedents, favourable prison reports indicating a scope for rehabilitation and legal precedents weighed against imposing capital punishment.
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The man was convicted of murdering his wife and daughters on the intervening night of November 11-12, 2011. The trial court and the Uttar Pradesh high court had both confirmed his conviction under Section 302 of the Indian Penal Code and awarded him the death penalty. However, in deciding whether the case met the threshold of “rarest of rare” for capital punishment, the Supreme Court carefully balanced aggravating and mitigating factors.
The court acknowledged the brutality of the crime, while simultaneously flagging that judicially determining a sentence must go beyond the nature of the offence and also assess the circumstances of the offender.
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Among the factors that led the apex court to commute the death sentence was the convict’s clean record before the incident, good prison records and absence of any material suggesting that he posed a continuing threat to society.
Referring to previous judgments, including State of Uttar Pradesh Vs Krishna Master (2010) and Prakash Dhawal Khairnar (2002), the court pointed out that even in cases where multiple homicides had been committed, the death penalty was not imposed when there was evidence of reform potential.
“This court has consistently recognised that the imposition of capital punishment is an exception and not the rule. Even where multiple murders have been committed, if there is evidence or at least a reasonable possibility of reform, a lesser sentence must be preferred,” noted the bench.
The bench concluded that while the crime deserved the strongest condemnation, it did not meet the standard of being so extreme that it would justify the irreversible punishment of death. The court ultimately commuted the man’s death sentence to life imprisonment without remission, ensuring that he would remain behind bars for the rest of his life.