VidhiSangh

Supreme Court of India · 09/12/2021

BHAGCHANDRA versus STATE OF MADHYA PRADESH

[2021] 9 S.C.R. 765 · 2021 INSC 851

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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

  1. Whether discrepancies and challenges to medical and recovery evidence undermined the convictions.
  2. Whether death was warranted after considering the offender’s circumstances and prospects of reform.

Provisions considered

Held

Result

Appeals partly allowed; convictions under Sections 302, 201 and 506-B IPC affirmed, but death sentence commuted to life imprisonment for thirty years.

Judgment PDF: Supreme Court of India, [2021] 9 S.C.R. 765.