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Bachan Singh v. State of Punjab (1980)

Case Summary


The case of Bachan Singh v. State of Punjab (1980) is a landmark legal proceeding that deals with the constitutionality of the death penalty in India. Bachan Singh was convicted of murder and sentenced to death under Section 302 of the Indian Penal Code (IPC). His appeal challenged the constitutional validity of the death penalty, arguing that it violated the fundamental right to life and personal liberty guaranteed under Article 21 of the Indian Constitution.


In its judgment delivered in 1980, the Supreme Court of India upheld the constitutionality of the death penalty while recognizing its exceptional nature. The court held that the death penalty could be imposed in the "rarest of rare" cases where the alternative punishment of life imprisonment would be grossly inadequate. The court established guidelines to determine the "rarest of rare" cases, considering factors such as the nature of the crime, the culpability of the offender, and the impact on society. The judgment emphasized the need for individualized sentencing and the importance of mitigating factors in capital sentencing.


The judgment in Bachan Singh v. State of Punjab had significant implications for the administration of criminal justice and the use of the death penalty in India. It provided a framework for assessing the appropriateness of capital punishment and established safeguards to prevent its arbitrary and excessive imposition. The "rarest of rare" doctrine introduced by the court became a cornerstone of death penalty jurisprudence, guiding judicial discretion and ensuring consistency in sentencing. Additionally, the judgment stimulated debates on the morality and efficacy of the death penalty, prompting calls for its abolition or further restrictions.

List of Linked Cases:

Machhi Singh v. State of Punjab (1983)

Rajendra Prasad v. State of Uttar Pradesh (1979)

Jagmohan Singh v. State of Uttar Pradesh (1973)

Mithu v. State of Punjab (1983)

Dhananjoy Chatterjee v. State of West Bengal (1994)

Santosh Kumar Satishbhushan Bariyar v. State of Maharashtra (2009)