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Supreme Court of India 2019-02-14 partly_allowed

Md. Mannan @ Abdul Mannan vs State of Bihar

Bench: 3 — Sanjay Kumar, Alok Aradhe

In Brief

A man convicted of rape and murder of an 8-year-old girl was sentenced to death. The Supreme Court reopened his review petition (previously dismissed by circulation) and commuted the death sentence to life imprisonment without remission. The Court held that while the crime was heinous, it was not the "rarest of rare" case meriting death. Key defects were: the trial court denied him a meaningful hearing on sentencing under CrPC Section 235(2); conviction relied on circumstantial evidence and extra-judicial confession without DNA testing; he lacked effective legal representation; and he had developed mental illness from prolonged solitary confinement. The Court emphasized that brutality alone does not justify death—the criminal's background, mental state, and capacity for reformation must be considered.

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