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Mohd. Firoz vs State of Madhya Pradesh

Criminal Appeal · 2022 INSC 429Decided 19 Apr 2022
Criminal Appeal No. 612 of 2019

Background

A 4-year-old girl was lured away from her family's courtyard by the appellant, who had come to the house asking for shelter for the night. She was found unconscious and badly injured the next morning and died days later; medical evidence confirmed she had been raped, and the cause of death was smothering. The appellant was convicted by the trial court and sentenced to death; a co-accused was convicted of a lesser role but was acquitted by the High Court. The High Court confirmed the death sentence for the appellant, who then appealed to the Supreme Court (originally filed by his mother, later continued by him after her death).

Decision Breakdown

The Supreme Court upheld the conviction based on strong circumstantial evidence: the child was last seen with the appellant shortly before she was found injured, DNA from hair at the scene matched the appellant, and he had fled to his native state before being arrested. However, applying the Constitution Bench's "rarest of rare" test for the death penalty, the Court held this case, while horrific, did not meet that exacting standard, noting other similar cases where death sentences had been commuted. It commuted the death sentence to life imprisonment for murder, and separately imposed 20 years' rigorous imprisonment (rather than imprisonment for the remainder of his natural life) for the aggravated sexual offence, balancing retribution with the possibility of reform.

Lesson Learnt

Even in the most horrific crimes against children, the death penalty can only be imposed after specifically finding the case falls in the "rarest of rare" category; courts must weigh mitigating factors and the possibility of reform before choosing between death and long-term imprisonment.

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

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