Introduction
The case dealt with the constitutionality of the death penalty under Section 302 of the Indian Penal Code (IPC). The appellant, Jagmohan Singh, challenged his death sentence, claiming it violated fundamental rights under Articles 14 (Right to Equality), 19 (Right to Freedom), and 21 (Right to Life) of the Indian Constitution.
Facts
Jagmohan Singh was convicted for murdering Chhotey Singh due to a longstanding personal dispute. He was sentenced to death by the Sessions Court, and the sentence was upheld by the Allahabad High Court. He then appealed to the Supreme Court, questioning the constitutional validity of the death penalty.
Issues
- Is the death penalty under Section 302 of IPC constitutionally valid?
- Does the death penalty violate Articles 14, 19, and 21 of the Indian Constitution?
- Does the death penalty involve excessive judicial discretion?
You can also read the Blog by visiting [Blog]
For more information, visit [Aashayein Enquiry Section]
Contentions of the Petitioner
The death penalty violates the right to life (Art. 21) and freedom (Art. 19), as it is arbitrary and lacks clear standards. The appellant argued that judicial discretion in imposing the death penalty is excessive and leads to arbitrary decision-making. The death penalty creates unequal treatment, as similar offenses may result in different punishments.
Contentions of the Respondent
The death penalty is constitutionally valid, as it is recognized in Articles 72 and 134 of the Constitution and IPC Section 302. Judicial discretion is necessary to account for unique circumstances in each case. Discretion in sentencing does not violate Article 14, as different sentences reflect the differing facts and circumstances of each case. The process followed is in accordance with the law (CrPC and IPC), ensuring a fair trial.
Court's Analysis
The Supreme Court upheld the constitutionality of the death penalty, emphasizing the following:
The Court held that capital punishment is permissible, as recognized by the framers of the Constitution, and is subject to judicial review and appeals (Article 72 and 134).
The Court upheld judicial discretion in sentencing, acknowledging that each case is unique and requires individual assessment. Citing State of Madras v. V.G. Row (1952), the Court affirmed that such discretion is not arbitrary.
The Court ruled that differing sentences for similar crimes are justified due to individual circumstances, citing Budhan Choudhary v. State of Bihar (1955).
The Court noted that the procedures followed, as per the CrPC, ensure that the accused is given due process before being sentenced to death.
The Supreme Court, by a unanimous decision, upheld the death sentence and dismissed the appeal, affirming that the death penalty is constitutional and not violative of the fundamental rights under Articles 14, 19, and 21.
Conclusion
This judgment reinforced the legitimacy of the death penalty in India while ensuring that judicial discretion is exercised fairly and with due consideration of all relevant factors. It emphasized the need for individual assessment in capital punishment cases and upheld the constitutional safeguards available to the accused.
