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Veerendra vs State of Madhya Pradesh

Not available · 2022 INSC 565Decided 13 May 2022
Not available
A.M. Khanwilkar · Dinesh Maheshwari · C.T. Ravikumar

Background

In September 2014 in Gwalior, Madhya Pradesh, an 8-year-old girl was sent by her family to buy a bidi bundle from a shop, where she was seen by the appellant, her mother's cousin (her "mama"/maternal uncle), who followed her and she went missing. After a search through the night, a missing complaint was filed; the next day the appellant was interrogated, arrested, and, based on his disclosure statement, the police recovered the victim's body hidden under gunny bags. Post-mortem and forensic reports established she had been raped in a brutal manner and killed by strangulation. The trial court convicted him of murder, aggravated sexual assault, and offences under the POCSO Act, sentencing him to death for murder; the Madhya Pradesh High Court confirmed the death sentence while setting aside one conviction (Section 376A) on a technical ground, prompting his appeal to the Supreme Court.

Decision Breakdown

The Supreme Court upheld the conviction, finding that the prosecution's circumstantial evidence: the "last seen" theory, the appellant's disclosure statement leading to recovery of the concealed body, and the forensic/medical evidence of rape and strangulation: formed a complete and unbroken chain pointing unerringly to his guilt, and that the absence of a DNA test did not weaken this chain since a negative or absent DNA result does not automatically favour the accused when other circumstantial evidence is conclusive. However, on the question of sentence, the Court held that the trial court and High Court had not properly applied the "crime test" and "criminal test" framework required before imposing the death penalty: while the brutality of raping and murdering an 8-year-old relative was a serious aggravating factor, the appellant's lack of any prior criminal record, his poor socio-economic background, his young age (25 at the time), and his good conduct in jail meant the case could not be treated as falling within the "rarest of rare" category demanding execution. Applying the principle from Swamy Shraddananda v. State of Karnataka, the Court commuted the death sentence to life imprisonment, but with a special condition that he serve an actual 30 years in prison without eligibility for premature release or remission, recognising that ordinary life imprisonment (which typically allows remission after around 14 years) would be inadequate for a crime of this gravity.

Lesson Learnt

Even where a brutal crime is proven beyond doubt through strong circumstantial evidence, the death penalty is reserved only for the "rarest of rare" cases after weighing both the crime's aggravating features and the offender's personal mitigating circumstances (age, criminal history, background, potential for reform); courts have the power to impose an extended, remission-free life sentence as a middle path between ordinary life imprisonment and execution.

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

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