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Yogendra @ Jogendra Singh v. The State of Madhya Pradesh

Criminal Appeal · 2019 INSC 54Decided 17 Jan 2019
Criminal Appeal Nos. 84-85 of 2019
Justice S.A. Bobde · Justice L. Nageswara Rao · Justice R. Subhash Reddy

Background

The appellant was convicted and sentenced to death by a Sessions Court, and the death sentence was confirmed by the Madhya Pradesh High Court, for murdering a woman, Smt. Ruby, by pouring acid on her, and for causing acid-burn injuries to three of her family members who tried to save her. The appellant, who believed the deceased had deserted him, snuck into her room at night and threw acid on her and others before fleeing; he was later arrested, and fingerprint evidence linked him to a beer bottle used to carry the acid. The dying declaration of the deceased, recorded by a magistrate while she was conscious, was treated as key evidence of guilt.

Decision Breakdown

The Supreme Court upheld the conviction, finding the evidence, including the dying declaration and eyewitness testimony of injured family members, "unimpeachable" and sufficient to prove guilt beyond reasonable doubt. However, on sentencing, the Court held that the case did not fall within the "rarest of rare" category required for a death sentence under the Bachan Singh and Machhi Singh precedents, since the attack, while brutal, appeared to stem from a personal relationship grievance rather than a cold-blooded premeditated plan to kill, and an earlier unrelated murder conviction of the appellant from a decade before could not by itself justify death as the only option. The Court therefore set aside the death sentence and converted it to life imprisonment, while otherwise confirming the conviction.

Lesson Learnt

A death sentence requires the court to find "special reasons" and that the case falls in the narrow "rarest of rare" category even where guilt is proven beyond doubt; courts are expected to treat life imprisonment as the rule and death as the exception, considering the specific circumstances of the crime and not a defendant's unrelated past record in isolation.

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

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