Landmark Supreme Court Cases on Sentencing

 

⚖ Landmark Supreme Court Cases on Sentencing

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1️⃣ Bachan Singh v. State of Punjab (1980)

Citation: AIR 1980 SC 898
Key point:

• Laid down the “rarest of rare” doctrine for imposing the death penalty.

• Held that life imprisonment is the rule, and death sentence is the exception.

• Courts must balance aggravating and mitigating factors before awarding the death sentence.

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2️⃣ Machhi Singh v. State of Punjab (1983)

Citation: AIR 1983 SC 957
Key point:

• Elaborated on the rarest of rare test.

• Gave guidelines: nature of the crime, manner of commission, motive, magnitude, and impact on society must be considered.

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3️⃣ Jagmohan Singh v. State of Uttar Pradesh (1973)

Citation: AIR 1973 SC 947
Key point:

• Upheld the constitutionality of the death penalty.

• Held that sentencing is done after considering circumstances and evidence, so it does not violate Article 21 (right to life).

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4️⃣ Mithu v. State of Punjab (1983)

Citation: AIR 1983 SC 473
Key point:

• Struck down mandatory death penalty under Section 303 IPC as unconstitutional.

• Held that courts must have discretion to consider mitigating factors.

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5️⃣ State of Punjab v. Prem Sagar (2008)

Citation: (2008) 7 SCC 550
Key point:

• Emphasized the need for proportionality in sentencing.

• Punishment should match the seriousness of the offence; excessive or unduly harsh punishments violate fundamental rights.

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6️⃣ Swaran Singh v. State of Punjab (2000)

Citation: (2000) 5 SCC 668
Key point:

• Highlighted that sentencing should aim at reformative justice when possible, not merely retribution.

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7️⃣ Santosh Kumar Satishbhushan Bariyar v. State of Maharashtra (2009)

Citation: (2009) 6 SCC 498
Key point:

• Reaffirmed the rarest of rare test but warned against arbitrary use of death penalty.

• Stressed the importance of individualized sentencing — the background of the accused matters.

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8️⃣ Mukesh & Anr v. State (Nirbhaya case) (2017)

Citation: (2017) 6 SCC 1
Key point:

• Applied rarest of rare doctrine to uphold the death sentence for the brutal gang rape and murder in Delhi.

• Emphasized collective conscience of society as a factor in sentencing.

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💡 Themes from these cases

✅ Sentencing is not mechanical — it requires judicial application of mind.
✅ Courts must weigh aggravating vs. mitigating factors.
✅ Reformative, deterrent, and retributive aims are all considered.
✅ Death penalty is reserved only for the gravest crimes.