Court’s Decision
The Chhattisgarh High Court, while affirming the conviction of six appellants in the brutal rape and murder of a 16-year-old minor girl, a 4-year-old child, and their guardian, commuted the death sentence awarded by the trial court. The Bench held that the trial court failed to comply with the guidelines laid down in Manoj v. State of Madhya Pradesh (2023) regarding sentencing in death penalty cases, especially with respect to the evaluation of the possibility of reformation and rehabilitation of the convicts. The Court thus modified the sentence to life imprisonment for the remainder of the natural lives of the five appellants and directed imprisonment for 30 years without remission in respect of the sixth appellant.
Facts
The victims, identified as ‘A’ (the guardian), ‘B’ (a 16-year-old girl), and ‘C’ (a 4-year-old child), were working at the house of one of the accused, Santram Manjhwar, grazing his cattle. A dispute over pending wages led the family to decide to return to their village. On the day of departure, the accused allegedly intercepted them at the bus stand under the pretext of giving them a lift. Instead, they were taken to a remote location. The prosecution alleged that ‘B’ was gangraped, ‘A’ and ‘C’ were killed by bludgeoning and strangulation, and ‘B’ was left to die after suffering severe sexual and physical assault.
The bodies were later recovered based on statements given during police interrogation, and the girl ‘B’ was initially found unconscious but was declared dead upon hospital admission.
Issues
- Whether the conviction based on circumstantial evidence, DNA, and forensic reports was sustainable?
- Whether the case fell within the “rarest of rare” category justifying the death penalty?
- Whether the trial court erred in failing to examine the possibility of reformation of the accused?
Petitioner’s Arguments
The convicts argued that the prosecution failed to prove the case beyond reasonable doubt. There were serious gaps in the chain of circumstantial evidence, lack of direct eyewitnesses, contradictions in witness testimonies, and inconclusive forensic results.
Counsel contended that the finger print and DNA reports were insufficiently corroborated. It was also argued that the trial court violated sentencing procedures laid down by the Supreme Court, failing to consider mitigating factors or the possibility of reformation. They placed reliance on precedents including Bachan Singh, Manoj, Swamy Shraddananda, and others to assert that the death penalty must be imposed only in the “rarest of rare” cases, which the present case allegedly did not qualify as.
Respondent’s Arguments
The State defended the convictions and the death penalty, highlighting the brutality of the crime—rape and murder of a minor girl, the murder of a 4-year-old child, and her guardian. It was submitted that the post-mortem findings, recovery of bloodstained weapons and clothes, fingerprint evidence, DNA match on the victim’s undergarments, and testimony of the deceased’s relatives firmly established the accused’s guilt.
The State emphasized the heinous and depraved nature of the crime and submitted that it warranted capital punishment.
Analysis of the Law
The Court thoroughly examined the legal standards under Section 354(3) of the Criminal Procedure Code for awarding a death sentence and reiterated that “special reasons” must be recorded to justify such punishment. The Court stressed the importance of following the “rarest of rare” doctrine evolved in Bachan Singh and reaffirmed in Manoj, which necessitates examining both aggravating and mitigating circumstances, including the possibility of reformation.
The Court found that the trial court had failed to call for reports regarding the conduct, psychological state, socio-economic background, or potential for reformation of the accused, and thus, the death sentence lacked procedural compliance.
Precedent Analysis
The Court relied heavily on:
- Manoj v. State of Madhya Pradesh (2023) – directing detailed pre-sentence reports, including psychiatric and social evaluations.
- Bachan Singh v. State of Punjab (1980) – laying down the “rarest of rare” principle.
- Machhi Singh v. State of Punjab (1983) – listing aggravating circumstances for awarding death.
- Swamy Shraddananda (2008), Raj Kumar (2014), Selvam (2014) – where life imprisonment with specific minimum terms was considered a suitable alternative to the death penalty.
- Mohd. Firoz v. State of Madhya Pradesh (2022) – emphasizing restorative justice and modifying death sentence to fixed-term imprisonment.
Court’s Reasoning
The High Court observed:
“The learned trial Court has not taken into consideration the probability of the convict/appellants to be reformed and rehabilitated… No opportunity of hearing was given to the convict/appellants to produce evidence in that respect.”
The Court concluded that the sentencing process was vitiated due to non-compliance with mandatory sentencing procedures and lack of evaluation of mitigating factors.
While the evidence—including FSL, DNA, medical reports, and eyewitness testimonies—was found sufficient to uphold the conviction, the sentence of death could not be sustained in the absence of adherence to procedural safeguards laid down by the Supreme Court.
Conclusion
The Chhattisgarh High Court affirmed the conviction of all six appellants for rape, murder, and other offences under the Indian Penal Code, POCSO Act, and the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act. However, the Court commuted the death sentence of five appellants to imprisonment for life for the remainder of their natural life and awarded 30 years of rigorous imprisonment without remission to the sixth.
Implications
This ruling reinforces the binding nature of the Manoj guidelines and highlights that procedural fairness in sentencing, particularly in death penalty cases, is not optional. The decision signifies a shift toward restorative justice and reiterates the constitutional mandate of individualized sentencing.
FAQs
1. What did the Chhattisgarh High Court say about the death sentence in this case?
The Court held that the trial court had failed to examine the possibility of reformation of the accused and did not follow the sentencing guidelines mandated by the Supreme Court. As a result, the death sentence was commuted to life imprisonment.
2. On what grounds were the convictions upheld despite circumstantial evidence?
The Court found that the circumstantial evidence, including DNA findings, fingerprint reports, recovery of incriminating materials, and medical evidence, formed an unbroken chain proving the guilt of the accused.
3. Why is the Manoj judgment important in death penalty cases?
Manoj v. State of MP mandates courts to consider reformation potential, socio-economic background, psychological evaluation, and jail conduct of the accused before sentencing them to death. It was not complied with in this case, leading to commutation of the sentence.
Also Read: Kerala High Court Dismisses Challenge to Electricity Charges for Private Hospitals
