SHATRUGHAN CHAUHAN & ANR. versus UNION OF INDIA & ORS.

SHATRUGHAN CHAUHAN & ANR. versus UNION OF INDIA & ORS.

Undue delay and supervening circumstances such as prolonged solitary confinement and mental illness after confirmation of death sentence by judicial process violate Article 21 and warrant commutation to life imprisonment; execution of death sentence must be in consonance with constitutional mandates and due procedure.

Parties
Petitioner: Shatrughan Chauhan; Respondent: Union of India
Jurisdiction
India
Judgment Date
21 January 2014
Procedural Posture
Writ Petition (criminal) No. 55 of 2013 / Final Disposal by Supreme Court
Outcome
Death sentences of all petitioners commuted to life imprisonment.
Legal Topics
Mercy Petition, Commutation of Death Sentence, Delay in Execution, Right to Life, Solitary Confinement, Judicial Review of Executive Orders, Procedure for Mercy Petition, Article 21 Rights, Article 32 Writ Petition
Constitutional Law Criminal Law Prison Law Mercy Petition Commutation of Death Sentence Delay in Execution Right to Life Solitary Confinement +4 more

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Parties

Shatrughan Chauhan

Petitioner

Union of India

Respondent

Procedural Posture

Writ Petition (criminal) No. 55 of 2013 / Final Disposal by Supreme Court

Legal Issues

  1. 1 Whether undue delay in disposal of mercy petitions warrants commutation of death sentence to life imprisonment.
  2. 2 Whether procedural lapses, insanity, and solitary confinement constitute supervening circumstances for commutation.
  3. 3 Scope of judicial review of executive orders under Article 72/161 of the Constitution.

Ratio Decidendi

Undue delay and supervening circumstances such as prolonged solitary confinement and mental illness after confirmation of death sentence by judicial process violate Article 21 and warrant commutation to life imprisonment; execution of death sentence must be in consonance with constitutional mandates and due procedure.

Court Disposition

Death sentences of all petitioners commuted to life imprisonment.

Orders

  • Writ petitions allowed.
  • Guidelines framed for handling mercy petitions and treatment of death row convicts.