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Jagdish v. The State of Madhya Pradesh

Review Petition (Criminal) · 2019 INSC 246Decided 21 Feb 2019
Review Petition (Criminal) No. 591 of 2014
Justice N.V. Ramana · Justice Deepak Gupta · Justice Indira Banerjee

Background

The petitioner was convicted of murdering his wife and five children and sentenced to death, a sentence confirmed by the High Court and then by the Supreme Court in 2009. His mercy petition to the President, filed in 2009, was rejected only in July 2014: a delay of nearly five years, largely because the Madhya Pradesh state government took over four years to forward the file to the Ministry of Home Affairs. He filed both a writ petition challenging the mercy-petition delay and a review petition against his conviction and sentence.

Decision Breakdown

The Supreme Court declined to reopen the conviction itself, noting three courts had concurrently found him guilty on the facts. However, relying on its earlier rulings (V. Sriharan and Ajay Kumar Pal) that unexplained, inordinate delay in deciding a mercy petition violates the convict's right to a fair process under Article 21, the Court found the State of Madhya Pradesh's unexplained four-year delay in forwarding the mercy petition to be a valid ground for relief. Combined with the fact that the petitioner had already spent about 14 years in custody, the Court commuted the death sentence to life imprisonment, but directed that this "life imprisonment" would mean imprisonment for his entire remaining natural life, with no possibility of release, given the severity of the crime (six lives lost). The review petition and writ petition were accordingly partly allowed and disposed of.

Lesson Learnt

Even where a conviction for a serious crime stands, the government cannot sit on a death-row convict's mercy petition indefinitely: unexplained, prolonged delay by state authorities in processing such petitions can itself be a constitutional ground for commuting a death sentence to life imprisonment.

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

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