INTRODUCTION
The supreme court of India has recently delivered a judgment in the case of Deena Dayal Tiwari v state of Uttar Pradesh (2025) which reduced the sentence from death sentence to life imprisonment. The cases involve the brutal killings of multiple murders and this case drew the attention of capital punishment. This judgment focused on the rehabilitation, mitigating factors, and the prior criminal history and the precedent on the imposition of death penalties in the multiple murder case by the judiciary. The supreme court upheld the conviction but modified the sentence by bringing the balance between justice, deterrence and the possibility of rehabilitation.
BACKGROUND
This case involves the appellant Deena Dayal Tiwari who is convicted for the horrific murder of his family consisting of his wife and his four minor daughters based on circumstantial evidence. The trial court convicted him for capital punishment; later it was upheld by the high court. However, the aggrieved party challenges the imposition of death penalty before the supreme court of India, stating that the offence doesn’t fall within the rarest of rare case category as mandated by the precedent set by Bachan Singh v state of Punjab (1980). The supreme court India considered the crime committed by the accused where it will fall under the criteria of death penalty under the ‘rarest of rare’ doctrine. This doctrine requires only in the exceptional cases a death sentence is imposed.
KEY POINTS
Mitigating factors:
- The supreme court notes that the appellant had no prior criminal record for commission of crime.
- Prison reports indicated and suggested about the good conduct and the chance of potential reform of the accused person of the crime
- There is no evidence suggesting that he the appellant is a perpetual threat to the society at large.
Reaffirmation of the rarest of rare doctrine:
- The supreme court mandated in the Bachan Singh v state of Punjab that death sentence is only imposed in the exceptional cases.
- The court noted that even in the multiple murder case if there is a possibility of reform, then life imprisonment should be preferred.
Precedents
- The supreme court referred the case state of Uttar Pradesh v Krishna master & Ors 2010 and Prakash Dhawal Khairnar v state of Maharashtra 2002 where the death penalty was commuted to life imprisonment even the convicts being involved in the crime of multiple murders.
- The case invoked the precedents Swamy Shraddanand v state of Karnataka 2008 which also conceptualized the concept of life imprisonment without remission as an alternative to the death penalty.
Rejection of state contention:
- The prosecution lighted the factor of gruesome nature of the crime warranted the death penalty and not the life imprisonment.
- The court cited the importance of the mitigating factors which overweighted the aggravating circumstance of the crime and justifying the commutation.
RECENT DEVELOPMENT
This case gives the significance of the evolving jurisprudence on capital punishment in India. The supreme court India judgment highlighted the paradigm shift to a reformative approach focusing on rehabilitation rather than retribution. The court considered the gravity of the offence and imposed the importance of the life imprisonment without remissions enough to uphold the justice rather than imposing the irrevocable punishment to death.
CONCLUSION
This judgment of Deen Dayal Tiwari v state of Uttar Pradesh reinforces the principle related to death penalty that is the ‘rarest of rare’ cases. The court emphasized the importance of comprehensive analysis of a convict’s circumstance from case to case before awarding the irreversible death penalty. Through this judgment the court balanced both the nature and gravity of the crime and the individual’s circumstance in the crime convicted.
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WRITTEN BY: MUTHULAKSHMI B
