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Eknath Kisan Kumbharkar vs. State of Maharashtra

Not available · 2024 INSC 779Decided 16 Oct 2024
Not available
Justice B.R. Gavai · Justice Aravind Kumar · Justice K.V. Viswanathan

Background

The appellant was convicted of murdering his own pregnant daughter, Pramila, who had married against his wishes in an inter-caste marriage. He lured her away from her matrimonial home under the pretext that his mother was dying and wished to see her, and then killed her. The Trial Court sentenced him to death under Section 302 IPC (along with sentences under Sections 316 and 364 IPC), and the Bombay High Court confirmed the death sentence. He appealed to the Supreme Court challenging the death sentence.

Decision Breakdown

The Supreme Court affirmed the conviction, agreeing the crime was gruesome and unquestionably grave, but declined to uphold the death penalty. Applying the "rarest of rare" doctrine, it held that a death sentence requires not just a heinous crime but proof that the convict has no possibility of reformation, and here, the appellant was 38 years old with no prior criminal record, had serious health issues (including a heart condition requiring angioplasty and speech problems), and had shown satisfactory conduct in prison for six years, none of which supported a finding that he was beyond reform. As a "middle path" between death and an ordinary life sentence (which remains open to remission), the Court converted the death sentence into a fixed term of 20 years' rigorous imprisonment, expressly barring him from seeking remission until he actually completes that full 20-year term.

Lesson Learnt

Even in horrific crimes, the death penalty cannot be imposed merely because the crime is grave. Courts must also find, as a separate requirement, that the convict has no possibility of reform; where that cannot be shown, a long fixed-term sentence without the possibility of early remission is the appropriate "middle path."

Official source (sci.gov.in)View Judgment (PDF)

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