The Supreme Court on October 8, 2025, dismissed the Union Government’s plea to modify the 2014 Shatrughan Chauhan guidelines for death row convicts. The Bench said the plea lacked merit and reaffirmed that procedural fairness under Article 21 cannot be compromised.
New Delhi: On October 8, 2025, the Supreme Court of Indiadismissed a modification application filed by the Union Government, which sought changes to the landmark 2014 judgment in Shatrughan Chauhan v. Union of India, the case that established detailed safeguards for the rights of death row prisoners.
A bench comprising Justice Vikram Nath, Justice Sandeep Mehta, and Justice NV Anjaria observed that the Centre’s plea had no merit.
The Union Government had requested modifications to make the guidelines more “victim-centric” and to impose stricter timelines for filing mercy and curative petitions in cases involving capital punishment.
The government had originally filed this modification plea in 2020, during the pendency of death warrants for the four convicts in the 2012 Delhi gangrape and murder case (Nirbhaya case).
At that time, repeated petitions filed by the convicts had delayed their execution, which was finally carried out in March 2020 after the Supreme Court rejected the convicts’ last appeal in a rare midnight sitting.
The 2014 Shatrughan Chauhan judgment had laid down comprehensive guidelines aimed at protecting the constitutional and human rights of prisoners sentenced to death. Some of the key directions included:
- Delay in deciding mercy petitions can be a valid ground for commuting a death sentence to life imprisonment.
- A 14-day period must be given between the rejection of a mercy petition and the execution of the sentence. This allows the convict to pursue any remaining legal remedies and mentally prepare for the execution.
The Supreme Court had emphasized that the right to life under Article 21 of the Constitution applies even to those sentenced to death. It had also stated that humane treatment and procedural fairness are non-negotiable in the criminal justice system.
ALSO READ: Karur Stampede Shock: TN BJP Leader Demands CBI Probe into Vijay’s TVK Rally Tragedy
During the hearing, Additional Solicitor General KM Nataraj argued that the current framework allows death row convicts to indefinitely delay their executions by filing mercy, review, and curative petitions at different intervals.
He added that this results in procedural misuse and causes
“mental trauma to the victims and their families.”
The Centre’s application sought several changes, including:
- Establishing a clear timeline for filing a curative petition after a review petition is dismissed.
- Requiring that a mercy petition be filed within 7 days of the issuance of the death warrant.
- Directing that execution must take place within 7 days of rejection of the mercy petition, even if co-convicts’ petitions are still pending.
The government argued that the existing guidelines under Shatrughan Chauhan fail to account for the psychological suffering of victims’ families and undermine the deterrent effect of capital punishment by permitting long delays.
After hearing all arguments, the bench held that the Union Government’s application lacked merit and did not require any modification of the 2014 guidelines.
The Court stressed that the principles established in Shatrughan Chauhan continue to strike the right balance between the rights of convicts and procedural justice, stating that due process cannot be sacrificed in the name of expediency.
Earlier, the Supreme Court had postponed the consideration of this plea until after the decision in State of Maharashtra v. Pradeep Yashwant Kokade (2024), in which the Court had directed all States and Union Territories to create dedicated cells for the prompt processing of mercy petitions in accordance with prescribed timelines.
With that case now decided, the Court opted not to alter the existing legal framework.
By rejecting the modification plea, the Supreme Court has reaffirmed that death penalty jurisprudence in India must remain rooted in constitutional morality and human rights protections, even in situations of public outrage or administrative inconvenience.
The ruling underlines that procedural fairness for convicts is not a weakness of the justice system, but rather a fundamental aspect of due process under Article 21 of the Constitution.
The case also saw participation from Square Circle Clinic, NALSAR University of Law, as an intervener, highlighting the ongoing academic and policy interest in maintaining a careful balance between victim rights and death row protections in India’s criminal justice system.
Case Title:
Shatrughan Chauhan v. Union of India, MA 265/2020 in W.P. (Crl.) No. 55/2013,
Click Here to Read Previous Reports on Trans Women
