Case Law Review Of Landmark Criminal Appeals
🏛️ 1. Kehar Singh & Others v. State (Delhi Administration), (1988) 3 SCC 609
Facts:
This case arose from the assassination of Prime Minister Indira Gandhi by her bodyguards on October 31, 1984. Kehar Singh, Beant Singh, and Satwant Singh were accused of conspiracy and murder. After trial, they were convicted and sentenced to death.
Legal Issues:
Whether the death sentence was justified.
Whether the accused had a fair trial.
Scope of judicial review in death penalty cases.
Judgment:
The Supreme Court upheld the conviction and death sentence of Kehar Singh and Satwant Singh. The Court observed that:
The evidence clearly established a pre-planned conspiracy.
The crime was an attack on the sovereignty of India.
The trial was fair and conducted according to law.
Significance:
Reinforced the principle that conspiracy can be proved through circumstantial evidence.
Demonstrated how courts balance fair trial rights with the gravity of offences.
Later used in discussions on capital punishment jurisprudence.
⚖️ 2. State of Uttar Pradesh v. Rajesh Gautam & Ors., (2003) 3 SCC 339
Facts:
The accused were charged with the murder of seven family members over a property dispute. They were sentenced to death by the trial court, and the High Court confirmed it. The matter came before the Supreme Court on appeal.
Legal Issues:
Whether the death penalty was appropriate.
Whether the prosecution proved guilt beyond reasonable doubt.
Judgment:
The Supreme Court commuted the death sentence to life imprisonment, holding that:
The prosecution failed to prove the case conclusively.
Benefit of doubt must go to the accused.
Sentencing should consider mitigating circumstances.
Significance:
Reinforced the “rarest of rare” doctrine for awarding death penalty (from Bachan Singh v. State of Punjab).
Emphasized judicial restraint in capital punishment.
⚖️ 3. Bachan Singh v. State of Punjab, (1980) 2 SCC 684
Facts:
Bachan Singh was convicted of murder and sentenced to death. He challenged the constitutional validity of the death penalty under Section 302 of the IPC and Section 354(3) of CrPC, claiming it violated Article 14 and Article 21 of the Constitution.
Legal Issues:
Is the death penalty unconstitutional?
What are the guidelines for imposing the death penalty?
Judgment:
The Constitution Bench (5 judges) upheld the constitutional validity of the death penalty but limited its use to the “rarest of rare” cases where:
The alternative of life imprisonment is unquestionably inadequate.
The circumstances show extreme culpability.
Significance:
Created the “rarest of rare” doctrine, now the foundation of Indian death penalty law.
Established judicial discretion with safeguards.
Balanced retribution and reformative justice.
⚖️ 4. State of Maharashtra v. Dhanraj Tamang, (1994) 2 SCC 222
Facts:
The accused, a police constable, was convicted of custodial death of a detainee. The trial court acquitted him, but the High Court convicted him. The case reached the Supreme Court on appeal.
Legal Issues:
Whether custodial violence violates constitutional rights.
Whether conviction based on circumstantial evidence was valid.
Judgment:
The Supreme Court upheld the conviction, ruling that:
Custodial violence is a serious breach of human rights.
Police officers have a special responsibility to uphold the law, not break it.
Circumstantial evidence can be sufficient when direct evidence is unavailable due to the nature of the crime.
Significance:
Strengthened human rights protection in custody.
Set precedent for accountability of police officers.
Cited in later cases like DK Basu v. State of West Bengal (1997) on custodial safeguards.
⚖️ 5. Navjot Sandhu alias Afsan Guru v. State (Parliament Attack Case), (2005) 11 SCC 600
Facts:
This case concerned the 2001 Parliament attack in which terrorists stormed the Parliament House. The accused included Afzal Guru, Shaukat Hussain, and others charged with conspiracy, murder, and waging war against India.
Legal Issues:
Validity of conviction based on electronic evidence.
Whether conspiracy was proven.
Whether the death penalty was justified.
Judgment:
The Supreme Court upheld the death sentence of Afzal Guru, stating that:
The evidence proved a deep-rooted conspiracy.
The attack was an assault on Indian democracy.
The punishment was proportionate to the gravity of the offence.
Significance:
Landmark on anti-terrorism law (POTA) interpretation.
Recognized the importance of electronic evidence.
Reinforced deterrence in national security offences.
⚖️ 6. Shreya Singhal v. Union of India, (2015) 5 SCC 1
Facts:
Although primarily a constitutional case, it has deep implications for criminal law. Section 66A of the Information Technology Act, 2000 criminalized sending “offensive” messages online. Many people were arrested under this vague law.
Legal Issues:
Whether Section 66A violated the freedom of speech under Article 19(1)(a).
Whether the section was vague and overbroad.
Judgment:
The Supreme Court struck down Section 66A as unconstitutional, holding that:
The provision was vague, arbitrary, and prone to misuse.
It violated Article 19(1)(a) and was not saved under Article 19(2).
Significance:
Landmark protection for digital free speech.
Limited criminalization of expression online.
Used to curtail misuse of criminal law in cyberspace.
✍️ Conclusion
| Case | Core Principle | Impact |
|---|---|---|
| Kehar Singh (1988) | Conspiracy & Death Penalty | Clarified fairness in political crimes |
| Rajesh Gautam (2003) | Rarest of Rare | Refined death penalty doctrine |
| Bachan Singh (1980) | Constitutional validity of death penalty | Set “rarest of rare” test |
| Dhanraj Tamang (1994) | Custodial Violence | Reinforced police accountability |
| Afsan Guru (2005) | Terrorism & Conspiracy | Validated electronic evidence |
| Shreya Singhal (2015) | Freedom of Speech | Prevented misuse of vague criminal laws |
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