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Tattu Lodhi @ Pancham Lodhi v. State of Madhya Pradesh

Criminal Appeal · Neutral citation not assigned (Criminal Appeal Nos. 292-293 of 2014)Decided 16 Sept 2016
Criminal Appeal Nos. 292-293 of 2014
Justice J. Chelameswar · Justice Shiva Kirti Singh · Justice Abhay Manohar Sapre

Background

The appellant was tried and convicted by a Sessions Court in Jabalpur, Madhya Pradesh for kidnapping a seven-year-old girl, sexually assaulting her, and murdering her, based on circumstantial evidence (being last seen with the victim, recovery of the body and blood-stained clothes from his house, etc.). The trial court sentenced him to death, and the Madhya Pradesh High Court confirmed the conviction and death sentence on reference. The appellant then appealed to the Supreme Court.

Decision Breakdown

The Supreme Court upheld the conviction, finding the chain of circumstantial evidence complete and reliable, and even noted the trial court had erred by convicting only for attempted (not completed) sexual assault given the medical evidence, though this could not be corrected since neither the State nor the complainant had appealed that point. On sentencing, however, the Court held that the case did not meet the "rarest of rare" threshold required to confirm a death sentence, relying on the Constitution Bench ruling in Union of India v. V. Sriharan and Swamy Shraddananda(2) v. State of Karnataka, which allow the Court to impose a specified minimum term of life imprisonment as a middle path between a 14-year ordinary life sentence and death. The Court commuted the death sentence to life imprisonment with a direction that the appellant not be released until he completes 25 actual years in prison.

Lesson Learnt

Even where a conviction for a brutal crime is confirmed, the Supreme Court can decline to confirm a death sentence if the case does not meet the strict "rarest of rare" standard, and can instead fix a specific extended minimum term (here, 25 years) of life imprisonment using its Article 142 powers: a sentencing middle ground citizens should know exists between ordinary life imprisonment and the death penalty.

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

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