Supreme Court Commutes Death Sentence to Life Imprisonment in Murder Case, Emphasizes Need for Reasoned Orders in Capital Punishment Appeals

SC stresses mandatory hearing under Section 235 CrPC and detailed reasoning for dismissal of death penalty challenges; reiterates independent scrutiny in ‘rarest of rare’ death penalty cases

In a landmark judgment delivered on November 1, 2018, the Supreme Court of India in the case of Babasaheb Maruti Kamble v. State of Maharashtra commuted a death sentence awarded by the trial and High Courts to life imprisonment with a minimum rigorous imprisonment term of 20 years. The apex court underscored the critical importance of judicial procedures that protect the rights of convicts, especially in capital punishment cases, by mandating a proper hearing on sentencing and requiring reasoned orders even at the stage of dismissal of Special Leave Petitions (SLPs).

The appellant, Babasaheb Maruti Kamble, was convicted under Sections 302 (murder), 376(2)(f) (aggravated rape), and 342 (wrongful confinement) of the Indian Penal Code. The Sessions Court had sentenced him to death for murder, life imprisonment for rape, and simple imprisonment for wrongful confinement. The High Court upheld these convictions and confirmed the death sentence.

However, Kamble challenged the High Court judgment before the Supreme Court through an SLP, which was dismissed in limine without reasons, prompting Kamble to file a review petition. The Supreme Court agreed that in cases involving the death penalty, dismissing petitions without giving reasons undermines the fair trial standards and the constitutional guarantee of justice. The apex court recalled the earlier dismissal and restored the SLP for a fresh hearing.

On merits, the Court found the evidence against Kamble, though circumstantial, to be strong and unbroken, establishing his guilt beyond reasonable doubt. The incriminating circumstances included multiple eyewitnesses seeing Kamble with the victim, discovery of the victim's body in Kamble’s house, recovery of her belongings, and corroborative medical and DNA evidence. Kamble failed to provide any credible explanation during his examination under Section 313 of the Criminal Procedure Code.

Despite upholding the conviction, the Supreme Court held that the case did not qualify as one of the “rarest of rare” cases warranting the death sentence. Citing the principles laid down in the landmark Bachan Singh case and subsequent judgments, the Court emphasized the importance of considering various mitigating factors such as the age of the accused (Kamble being over 60), absence of prior criminal record, possibility of reform, and the nature of the crime. Taking these factors into account, the Court commuted the death sentence to life imprisonment with a stipulation that Kamble must serve at least 20 years of rigorous imprisonment before being eligible for remission.

Importantly, the Court reiterated that Section 235(2) of the Criminal Procedure Code mandates a proper hearing of the accused on the question of sentence, which goes beyond mere formalities to include the presentation of all relevant mitigating factors. The judgment highlighted the evolving standards of decency and due process in sentencing, underscoring the constitutional dignity owed to every individual, even convicted criminals.

The Court also emphasized the role of the Supreme Court as an independent fact-finder in death penalty cases, unbound by trial and High Court findings, and the necessity for reasoned orders at every stage, especially when a death sentence is affirmed or dismissed without detailed reasoning.

This ruling reinforces the careful and humane approach required in capital punishment jurisprudence in India, balancing the demands of justice, deterrence, and rehabilitation.

Statutory provisions

Indian Penal Code Section 302, 376(2)(f), 342; Criminal Procedure Code Sections 235(2), 313

---

This news report summarizes the Supreme Court's judgment in Babasaheb Maruti Kamble v. State of Maharashtra, highlighting the Court's insistence on procedural fairness, detailed reasoning in death penalty appeals, and the commutation of the death sentence to life imprisonment with a minimum term, consistent with evolving jurisprudential standards.

Babasaheb Maruti Kamble v. State of Maharashtra (SC) : Law Finder Doc Id # 1290924