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Supreme Court of India 2022-01-18 partly_allowed

Bhagwani vs State of Madhya Pradesh

Bench: 3 — L. Nageswara Rao

In Brief

An 11-year-old girl was raped and murdered in Madhya Pradesh in April 2017. The appellant and co-accused Satish were convicted based on circumstantial evidence including DNA matching of Satish, scratch injuries on both accused, their admission to visiting the victim's house, and their suspicious behaviour the next morning. The trial court imposed death sentences. The Supreme Court upheld the conviction but commuted the death sentence to 30 years' rigorous imprisonment. While acknowledging the brutal nature of the crime, the Court found that the state failed to prove the appellant could not be reformed, contrary to the mandatory requirement in capital cases. The Court also criticized procedural violations including conviction and sentencing on the same day, violating fair trial rights under Article 21.

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Criminal Law Sexual Offences Child Protection Death Penalty Sentencing Circumstantial Evidence Criminal Procedure Constitutional Rights Fair Trial Mitigation in Capital Cases

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