Introduction
The case of Bachan Singh v. State of Punjab (1980) is a landmark judgment by the Supreme Court of India that addressed the constitutional validity of the death penalty. This case introduced the “rarest of rare” doctrine, which continues to guide courts in capital punishment cases.
Case Overview
CITATION: AIR 1980 SC 898; (1980) 2 SCC 684
JUDGES: Y.V. Chandrachud, C.J., A.C. Gupta, N.L. Untwalia, P.N. Bhagwati, R.S. Sarkaria, JJ.
DATE OF DECISION: May 9, 1980
FACTS
Bachan Singh was convicted of the murders of Desa Singh, Durga Bai, and Veeran Bai under Section 302 of the Indian Penal Code (IPC), 1860. He was sentenced to death by the trial court, and the Punjab and Haryana High Court upheld this decision. Bachan Singh appealed to the Supreme Court, raising questions about the constitutional validity of the death penalty and the sentencing procedure outlined in Section 354(3) of the Code of Criminal Procedure (CrPC), 1973.
Also Read: I.C. Golak Nath v. State of Punjab
Issues
- Is the death penalty for murder under Section 302 of the IPC constitutionally valid?
- Does the sentencing procedure under Section 354(3) of CrPC, 1973, violate fundamental rights?
Judgment Highlights
The Supreme Court upheld the constitutional validity of the death penalty by a 4:1 majority. The Court made the following key observations:
- Constitutional Validity: The Court ruled that the death penalty does not violate Articles 19 or 21 of the Constitution. It held that the provision is not unreasonable or against public interest.
- Rarest of Rare Doctrine: The judgment introduced the “rarest of rare” doctrine, stating that the death penalty should only be imposed in exceptional cases where life imprisonment is unquestionably inadequate.
- Special Reasons Requirement: Section 354(3) of CrPC mandates that “special reasons” must be recorded for imposing a death sentence. These reasons should stem from the gravity of the crime and the circumstances surrounding it.
- Judicial Discretion: The Court emphasized that judges must evaluate both mitigating and aggravating factors to decide whether the death penalty is warranted.
Held
The Supreme Court upheld the constitutionality of the death penalty under Section 302 IPC and Section 354(3) CrPC. The Court clarified that capital punishment is not a routine punishment and should be applied only in the rarest of rare cases.
Significance
This case is a milestone in Indian criminal jurisprudence. It set a high threshold for awarding the death penalty, ensuring it is used sparingly and judiciously. The judgment balances the need for justice with the dignity of human life.
FAQs
1. What is the “rarest of rare” doctrine?
The “rarest of rare” doctrine, established in Bachan Singh v. State of Punjab, limits the imposition of the death penalty to cases where the crime is exceptionally brutal, and life imprisonment is inadequate.
2. Why was the death penalty upheld in this case?
The Supreme Court ruled that the death penalty does not violate the fundamental rights enshrined in the Constitution. It serves as a necessary punishment for heinous crimes where alternative options are insufficient.
3. What does Section 354(3) of CrPC require?
Section 354(3) CrPC requires courts to record “special reasons” for imposing a death sentence. These reasons must reflect the exceptional nature of the crime and justify the punishment.
Conclusion
The Bachan Singh judgment is a pivotal case that ensures the death penalty is applied with caution and in extreme cases. It safeguards human dignity while upholding the rule of law, making it a cornerstone of Indian legal jurisprudence.
Reference: blog.ipleaders