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Supreme Court of India 2023-11-09 partly_allowed

MADAN vs STATE OF UTTAR PRADESH

Bench: 3 — B.R. Gavai, B.V. Nagarathna, Prashant Kumar Mishra

In Brief

In this case, the Supreme Court upheld the conviction of appellant Madan under Section 302 IPC for his role in a brutal mass shooting that killed six people in a village dispute rooted in political rivalry over Gram Panchayat elections. The conviction rested on credible eyewitness testimony despite some inconsistencies and investigative lapses. However, while acknowledging the heinous nature of the crime, the Court held it did not constitute a 'rarest of rare' case warranting death penalty. The Court commuted Madan's death sentence to life imprisonment for a fixed term of 20 years without remission, considering his age (64), 18+ years of good conduct in prison, and lack of evidence proving irreformability. This middle-path approach aligned with the 'life as rule, death as exception' principle and eliminated the anomaly created by the High Court's disparate sentences for co-accused despite identical roles.

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Criminal Law Murder Capital Punishment Sentencing Eyewitness Testimony Mitigating Circumstances Life Imprisonment Criminal Procedure

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