Case Title: Sachin Kumar Singhraha v. State of Madhya Pradesh
The Supreme Court observed that the death penalty should only be used when life imprisonment seems to be an entirely inappropriate punishment while commuting a man's death sentence for raping and killing a five-year-old girl in the present case.
In the aforementioned case, the deceased child was an LKG student who was brutally assaulted and raped and succumbed to the injuries inflicted upon her. Although there were certain inconsistencies in the evidence on record and procedural errors had been brought to light, the Apex court bench noted that these do not justify granting the accused the benefit of the doubt when affirming the conviction that the Trial court had recorded.
The Court was of the view that there can be no disagreement over the widely accepted idea that the circumstances from which it is appropriate to infer guilt "should be" completely proven, not just "may" be proven. The facts must be so well-established that they only lead to the accused being guilty of the alleged offences. The chain of evidence must be conclusive enough to rule out any rational basis for the judgement that the accused is innocent and must demonstrate that, in all likelihood, the accused is the one who committed the crime.
The Apex Court observed that the Trial Court and the High Court had correctly concluded that the prosecution has proven its case for the offence with which the accused/appellant was charged beyond a reasonable doubt in light of all of the relevant facts and circumstances of the case. However, the Apex Court also opined that both the Trial Court and the High Court might not have been justified in giving the Accused/Appellant the Death Penalty.
It is clearly established that the death sentence serves as an exception to the rule of life imprisonment. Only when life imprisonment appears to be an entirely unsuitable punishment in light of the pertinent facts and circumstances, may the death penalty be applied. Heavy reliance was placed by the court on Santosh Kumar Singh v. State through CBI, wherein the Court observed that, sentencing is a tough assignment that frequently perplexes the court, therefore if given the choice between life sentence and death penalty, the lesser punishment is appropriate if the court finds it difficult to impose one or the other.
The bench on deciding to impose the death penalty on the appellant/accused by weighing the acute and extenuating factors of the present matter, stated that it cannot be concluded that the accused has a low likelihood of reforming given the absence of past criminal history and in light of his entire conduct the bench stated that death penalty is not warranted in this case. Therefore, keeping the totality of facts and circumstances in the present case, the bench opined that the crime in question may not necessarily come within the category for which the death penalty must be inflicted. However, it observed that the sentence of life imprisonment (with remission) without the possibility of parole in the present case would be wildly insufficient given the aggravating circumstances of the crime as described above.
The Apex Court then referring to its decision in Parusuram v. State of M.P. in respect of non-remissible sentencing, observed that in the current matter in hand, it is appropriate to sentence the appellant/accused to life imprisonment with a minimum of 25 years behind bars (without remission) and upheld the decision and order of the High Court upholding the appellant's conviction for crimes punishable under Sections 376(A), 302, and 201(II) of the IPC as well as Sections 5(i)(m) read in conjunction with Section 6 of the POCSO Act.