Sachin Kumar Singhraha v. The State of Madhya Pradesh

Criminal Appeal · 2019 INSC 350Decided 12 Mar 2019
Criminal Appeal Nos. 473-474 of 2019
Justice N.V. Ramana · Justice Mohan M. Shantanagoudar · Justice Indira Banerjee

Background

The accused, who drove a vehicle, was entrusted with safely taking a five-year-old girl to school after her uncle (who had travelled with her) alighted midway on the accused's assurance. The child never reached school and was later found to have been sexually assaulted and murdered; her body and school bag were recovered based on the accused's own disclosure statement. The trial court convicted him under Sections 363, 376(A), 302 and 201(II) IPC and the POCSO Act and sentenced him to death, and the Madhya Pradesh High Court confirmed the conviction (except acquitting him on the kidnapping charge) and the death sentence.

Decision Breakdown

The Supreme Court upheld the conviction, finding the chain of circumstantial evidence, custody of the child being handed to the accused, his being the last person seen with her, the recovery of the body and bag on his disclosure, and his false explanation for events that day (contradicted by school attendance records), complete and conclusive. However, on sentencing, the Court held that although the crime was heinous and premeditated, it did not fall within the "rarest of rare" category warranting death, since life imprisonment was not shown to be an inappropriate punishment and there was no history of prior offending. Applying its power to impose a non-remissible fixed-term sentence (as recognised in Swamy Shraddananda and Union of India v. V. Sriharan), the Court commuted the death sentence to 25 years' rigorous imprisonment without remission, setting off the roughly four years already undergone.

Lesson Learnt

Even where guilt in a brutal crime is proven beyond doubt, the death penalty is reserved for the "rarest of rare" cases; courts can and do substitute it with a long, non-remissible prison term when the facts don't clear that exceptional threshold.

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