Arvind Singh v. The State of Maharashtra
Background
An eight-year-old boy was kidnapped from outside his apartment in Nagpur in September 2014 by two young men, one of whom (A-1) had previously worked at the boy's father's dental clinic and held a grudge over his low salary and a dispute about overcharging a patient. A ransom demand of several crores was made to the boy's father, but the child was found murdered the next day, hidden under a bridge. Both accused were convicted by the trial court for kidnapping for ransom and murder and sentenced to death, a sentence the Bombay High Court (Nagpur Bench) confirmed on appeal.
Decision Breakdown
The Supreme Court examined extensive circumstantial evidence, eyewitness identifications, CCTV footage from a petrol pump, call records, and recovery of the body and incriminating articles based on the accused's disclosure statements, and upheld the conviction of both men under Sections 302 (murder) and 364A (kidnapping for ransom) read with Section 34 of the IPC, rejecting arguments that the timeline of events created doubt about when the child died. However, on sentencing, the Court held that the case did not meet the "rarest of rare" threshold required for a death penalty, noting the accused's young age and applying the principle from earlier rulings that life imprisonment is the rule and death the exception. It commuted the death sentence to life imprisonment with a specific direction that there be no remission until the convicts complete 25 years in prison.
Lesson Learnt
Even in horrific crimes against children, the Supreme Court applies a strict "rarest of rare" standard before confirming a death sentence, and will substitute a long, remission-free prison term instead where that standard is not met, showing that conviction and sentence are assessed as separate, independent questions.