Death Sentence Cannot Be Mechanical: SC Slams Trial Court for Passing Capital Punishment Without Following Sentencing Guidelines

"The manner in which the trial court proceeded to pass the sentencing order indicates hot haste leaving much to be desired" – In a critical ruling on October 8, 2025, the Supreme Court of India overturned the death sentence and conviction of an accused, holding that the sentencing process in the trial court was not only flawed but constitutionally impermissible. The bench comprising Justices Vikram Nath, Sanjay Karol, and Sandeep Mehta ruled that the death penalty was imposed in "hot haste", without any sentencing hearing, in violation of Article 21 of the Constitution and the mandatory guidelines laid down in Bachan Singh v. State of Punjab and subsequent rulings.

"Capital Punishment Is Not a Routine Sentence – Sentencing Must Be an Independent, Judicious, and Informed Exercise"

The Supreme Court held that the trial court’s decision to impose the death sentence on the very same day as the conviction — without any separate sentencing proceedings or analysis of aggravating and mitigating circumstances — violated settled legal procedure and constitutional safeguards.

“The conviction of the appellant was recorded on 19th February, 2018, and on the very same day, the learned trial Judge proceeded to undertake a pretentious exercise of hearing the appellant on the aspect of sentence and awarded the death penalty to him.”

The Court underscored that the imposition of the death sentence cannot be automatic and requires a thorough, independent sentencing hearing, especially in light of the rarest of rare doctrine laid down in Bachan Singh v. State of Punjab, (1980) 2 SCC 684.

“Neither the trial Court nor the High Court undertook the mandatory exercise of seeking a report of mitigating and aggravating circumstances; the psychological examination report of the appellant and a report concerning the conduct of the appellant in jail, before passing the order of sentence and confirming the same.”

The case concerned the alleged rape and murder of a 7-year-old child by her neighbour, the appellant, Dashwanth. The Trial Court convicted him under Section 302 IPC and Section 6 r/w Section 5(m) of the POCSO Act, among others, and awarded the death penalty on February 19, 2018—the same day it delivered the judgment of conviction.

The sentence was confirmed by the Madras High Court on July 10, 2018, without any meaningful sentencing analysis. The Supreme Court, however, found that no psychological or sociological assessment was ever conducted, and the conduct of the accused in jail was never considered, thereby rendering the entire sentencing exercise legally unsustainable.

"Sentencing Requires Deliberation – Not Formality"

Citing multiple precedents including Santa Singh v. State of Punjab (1976), Allauddin Mian v. State of Bihar (1989), Malkiat Singh v. State of Punjab (1991), and Dattaraya v. State of Maharashtra (2020), the Court emphasized the two-stage sentencing procedure in capital cases.

“The sentencing procedure is in direct conflict with the judgments of this Court... The exercise was a mere formality and no proper opportunity was provided to the appellant in the said process.”

It further observed: "Evidently, the manner in which the trial Court proceeded to pass the sentencing order indicates hot haste leaving much to be desired and would vitiate the death sentence awarded to the appellant."

Fair Trial Cannot End at Conviction – Sentencing is Integral

The Court was categorical in holding that Article 21 protections do not end with conviction and that sentencing, especially in capital punishment cases, is an integral part of a fair trial.

“In a case where accused is facing charges for offences which carry capital punishment, this constitutional mandate becomes even more sacrosanct, and it is the duty of the Court as well as the State to ensure that the accused is not prejudiced or deprived of a fair opportunity.”

It went on to lay down minimum procedural standards for sentencing in capital offences:

• Separate hearing on sentencing must be held after conviction.

• Reports on psychological health and jail conduct must be procured.

• Defence must be given real opportunity to present mitigating factors.

• Trial courts must record detailed findings on why death sentence is justified.

Supreme Court Quashes Death Sentence and Acquits Accused

Finding that the sentencing process was constitutionally defective, the Court ultimately not only set aside the death sentence but also acquitted the appellant, holding that the prosecution failed to prove guilt beyond reasonable doubt on all material aspects, including last seen theory, CCTV evidence, confession, and forensic linkages.

"As these vital circumstances have not been proved beyond all manner of doubt, it would not be safe to uphold the conviction of the appellant as recorded by the trial Court and affirmed by the High Court."

The judgment sets a powerful precedent on procedural sanctity in death penalty cases, reiterating that haste, procedural shortcuts, and presumptions have no place in capital sentencing.

Date of Decision: October 08, 2025