Summary
The Court affirmed convictions for three family murders, concealment-related conduct and intimidation, but commuted death to life imprisonment for thirty years. Credible eyewitness evidence established guilt despite minor discrepancies and exclusion of one unreliable witness. Sentencing had focused on brutality without adequate consideration of the offender or a meaningful opportunity to present mitigation. His lack of antecedents, poor rural background and satisfactory prison conduct, together with absence of State evidence excluding reform, did not justify death.
Issues
- Whether discrepancies and challenges to medical and recovery evidence undermined the convictions.
- Whether death was warranted after considering the offender’s circumstances and prospects of reform.
Provisions considered
- Section 354(3), Code of Criminal Procedure, 1973The special-reasons requirement called for assessment of both crime and offender, including serious consideration of reformation before imposing death. (¶ 41-44)
Held
- The principal eyewitnesses consistently proved the assaults and were corroborated by prompt disclosure, other witnesses and the FIR. One witness’s unnatural conduct made reliance on him inappropriate, but the remaining evidence independently established guilt. Minor discrepancies not affecting the core account did not require acquittal. (¶ 22-34)
- Credible direct evidence accorded with the post-mortem injuries. The challenges concerning the axe recovery and inconclusive serology did not defeat that independently established case; the Court did not need to treat those disputed circumstances as proved. (¶ 35-39)
- Death was exceptional, and brutality alone could not determine the rarest-of-rare inquiry. The offender’s circumstances and probability of rehabilitation required consideration, with the State obliged to produce evidence supporting exclusion of reform. (¶ 41-44)
- Conviction and death sentence had been imposed on the same day without an apparent meaningful opportunity to present sentencing material. The courts below had focused on the crime and failed adequately to consider the offender, his background and mitigating circumstances. (¶ 43)
- The appellant had no criminal antecedents, came from a poor rural background and had satisfactory prison conduct. The State supplied no evidence excluding reform. Those circumstances left the lesser-sentence alternative open, while the three gruesome murders warranted life imprisonment for thirty years. (¶ 44-46)
Result
Appeals partly allowed; convictions under Sections 302, 201 and 506-B IPC affirmed, but death sentence commuted to life imprisonment for thirty years.