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Manoj Pratap Singh vs. The State of Rajasthan

Criminal Appeal · 2022 INSC 652Decided 24 Jun 2022
Criminal Appeal Nos. 910-911 of 2022
A.M. Khanwilkar · Dinesh Maheshwari · C.T. Ravikumar

Background

The appellant was convicted of kidnapping a seven-and-a-half-year-old physically and mentally challenged girl from in front of her parents' fruit-and-vegetable cart, taking her to a secluded place, raping her, and killing her by inflicting fatal head injuries. The case rested entirely on circumstantial evidence: the victim was last seen with the appellant, the dead body and related articles were recovered based on his disclosures, he could not satisfactorily explain his whereabouts, and forensic/medical evidence matched the prosecution's case. The Trial Court convicted him under Sections 363, 365, 376(2)(f) and 302 IPC and Section 6 of the POCSO Act, and awarded him the death sentence for murder; the Rajasthan High Court, treating the crime as "rarest of rare," confirmed both the conviction and the death sentence. He appealed to the Supreme Court challenging both.

Decision Breakdown

After extensively reviewing the chain of circumstantial evidence (last-seen testimony, recoveries at the appellant's instance, forensic (FSL) reports, and medical evidence) the Court found the chain of circumstances complete and conclusive of guilt, rejecting arguments about investigation lapses, hurried trial, and inadequate legal aid, and upheld the conviction. On sentencing, applying the "rarest of rare" doctrine from Bachan Singh and Machhi Singh, the Court weighed aggravating factors: the extreme brutality of the crime against a disabled child, use of a stolen motorcycle, the appellant's history of prior criminal cases, and critically, his conviction for murdering a fellow jail inmate after this case's conviction: against mitigating factors like his young age (28) and family responsibilities. Finding no realistic probability of reform or rehabilitation given his continued violent conduct even in custody, and declining to order a psychological evaluation report as unwarranted on these facts, the Court held it a case with "no other option" but to confirm the death sentence, and dismissed the appeals.

Lesson Learnt

In death penalty cases, courts weigh aggravating and mitigating circumstances relating to both the crime and the criminal as a whole, including conduct after conviction, and a demonstrated pattern of continuing violent, incorrigible behaviour (even while incarcerated) can be decisive in confirming a death sentence over commutation, because it undermines any realistic possibility of reform.

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

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