SHATRUGHNA BABAN MESHRAM versus STATE OF MAHARASHTRA

SHATRUGHNA BABAN MESHRAM versus STATE OF MAHARASHTRA

The Supreme Court held that the circumstantial evidence proved a complete and consistent chain establishing the appellant’s guilt for the sexual assault and death of the two-and-a-half-year-old victim (convictions under relevant sections of IPC and POCSO affirmed). Considering the nature of injuries, the appellant was guilty of culpable homicide amounting to murder under clause fourthly of s.300 IPC; however, because there was no requisite intent falling under the first three clauses of s.300, the death sentence under s.302 IPC was not warranted and was commuted to life imprisonment. The death sentence under s.376A IPC was also not warranted and was reduced to rigorous imprisonment for 25...

Parties
Appellant/accused: Shatrughna Baban Meshram; Respondent: State of Maharashtra
Jurisdiction
India
Judgment Date
02 November 2020
Procedural Posture
Criminal Appeal / Appeal to Supreme Court (judgment)
Legal Topics
Rape, Murder, Culpable Homicide, Death Penalty, Protection of Children From Sexual Offences Act, Circumstantial Evidence, Ex Post Facto, Residual Doubt, Criminal Procedure (sentence Hearing)
Criminal Law Constitutional Law Sentencing Law Rape Murder Culpable Homicide Death Penalty Protection of Children From Sexual Offences Act +4 more

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Parties

Shatrughna Baban Meshram

Appellant/accused

State of Maharashtra

Respondent

Procedural Posture

Criminal Appeal / Appeal to Supreme Court (judgment)

Legal Issues

  1. 1 Whether the circumstantial evidence established guilt beyond reasonable doubt
  2. 2 Whether the acts committed fall within culpable homicide amounting to murder under clauses of s.300 IPC
  3. 3 Whether the death sentence was warranted (rarest of rare) and whether a lesser sentence was foreclosed

Ratio Decidendi

The Supreme Court held that the circumstantial evidence proved a complete and consistent chain establishing the appellant’s guilt for the sexual assault and death of the two-and-a-half-year-old victim (convictions under relevant sections of IPC and POCSO affirmed). Considering the nature of injuries, the appellant was guilty of culpable homicide amounting to murder under clause fourthly of s.300 IPC; however, because there was no requisite intent falling under the first three clauses of s.300, the death sentence under s.302 IPC was not warranted and was commuted to life imprisonment. The death sentence under s.376A IPC was also not warranted and was reduced to rigorous imprisonment for 25...