Aman Singh & Anr. v. State of Bihar
Background
This is an interim order (not a final judgment) in a death-sentence appeal arising from a Patna High Court judgment confirming a death reference and dismissing a related criminal appeal. The Supreme Court granted leave and, pending final hearing, stayed execution of the death sentence against the appellants Aman Singh and Sonal Singh. The Court then used the occasion to address a recurring systemic problem it has observed across death penalty cases: mitigating-circumstances reports for convicts are often not collected early enough in the trial or High Court stages, and legal representation in such cases is frequently inadequate.
Decision Breakdown
Rather than deciding the appeal's merits, the Court issued extensive procedural directions. It ordered Bihar's prison authorities and probation officers to prepare reports on the appellants' conduct, work, and psychological evaluation within 16 weeks, and permitted mitigation investigators from NALSAR University's Square Circle Clinic confidential access to interview the appellants in jail. Citing its earlier decision in Manoj v. State of Madhya Pradesh, the Court directed that going forward, trial courts must call for mitigating/aggravating-circumstances reports at the sentencing stage itself (not first at the Supreme Court appeal stage), that High Courts must call for such reports if missing when a death reference is admitted, and that Legal Services Committees must assign a dedicated legal team (one senior counsel plus two experienced advocates) to every death-reference case regardless of whether private counsel is engaged. It also directed NALSAR and the National Legal Services Authority to develop standardized guidelines for gathering mitigation information.
Lesson Learnt
In death penalty cases, Indian courts are now required to systematically investigate a convict's background, mental health, and potential for reform at the earliest stage of trial, not just at the final appellate stage, and every death-referred convict is entitled to a dedicated, adequately experienced legal team as a matter of course, reflecting the principle that death sentencing must be individualized and evidence-based, not purely retributive.