Case Brief: Bachan Singh v State of Punjab | Important Acts and Laws for Judiciary Exams PDF Download

Facts of Bachan Singh v State of Punjab

• Bachan Singh was tried, convicted, and sentenced to death under Section 302 of IPC 1860 for the murder of Desa Singh, Durga Bai, and Veeran Bai.
• The High Court confirmed his death sentence, which led him to appeal to the Supreme Court.
• A bench of the Supreme Court directed the case records to be submitted to the Chief Justice to resolve the question of the constitutional validity of the death penalty for murder.

Issue

• The main issue revolved around the constitutional validity of the death penalty for murder as per Section 302 of IPC and the sentencing procedure outlined in Section 354(3) of CrPC, 1973.

Judgment of Bachan Singh v State of Punjab

• The constitutionality of the provisions in Sec 302 of IPC, 1860 and 354(3) of CRPC, 1973 is being questioned.
• Various circumstances exist that may justify a milder sentence due to mitigating factors alongside aggravating circumstances.
• These factors cannot be precisely quantified by the judicial system due to the complexities of society.
• Respect for human life necessitates a reluctance to resort to capital punishment unless absolutely necessary.
• Sec 354(3) mandates that death penalty should not be imposed unless there are "special reasons" recorded for such a sentence.
• The term "special reasons" implies exceptionally grave circumstances specific to the crime in question.

Held

• The Supreme Court, in 1980, upheld the provision of the death penalty as a punishment for murder under section 302.
• The Court emphasized that the death penalty is not unreasonable or against public interest.
• It was clarified that the death penalty does not violate the principles of Article 19 of the Indian Constitution.
• The exercise of discretion under section 354(3) of the CRPC should be reserved for exceptional and grave circumstances.
• The imposition of the death sentence should be limited to the "rarest of rare" cases.

Explanation:

• In 1980, the Supreme Court reaffirmed that the death penalty for murder is constitutionally valid, emphasizing its exceptional nature.
• For example, in cases where the crime is particularly heinous or poses a severe threat to society, the death penalty may be considered.