The Supreme Court overturns its own death penalty verdict, ordering a fresh hearing in a rape-murder convict case, marking a historic shift in capital punishment jurisprudence.
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NEW DELHI: The Supreme Court of India has held that it can revisit its own verdict on the death penalty if it is convinced that the accused was condemned without adherence to the procedural safeguards mandated by the Court itself.
The Case of Vasanta Sampat Dupare
In the case of Vasanta Sampat Dupare, convicted for the rape and murder of a four-year-old girl. In 2017, the Supreme Court upheld Dupare’s death sentence.
However, in a fresh judgment, the Court has directed a rehearing on his punishment, citing non-compliance with the guidelines laid down in the landmark 2022 case of Manoj v. State of Madhya Pradesh.
Article 32 and Reopening of Sentencing
Delivering its ruling, a three-judge bench comprising Justices Vikram Nath, Sanjay Karol, and Sandeep Mehta observed that Article 32 of the Constitution empowers the Supreme Court to reopen the sentencing stage in capital punishment cases. The Court clarified that this corrective power must be exercised where there has been a violation of safeguards critical to upholding fundamental rights under Articles 14 and 21.
The Court stated:
“Article 32 of the Constitution empowers this Court in cases related to capital punishment to reopen the sentencing stage where the accused has been condemned to the death penalty without ensuring that the guidelines mandated in Manoj were followed.”
The Manoj Guidelines
In Manoj v. State of Madhya Pradesh (2022), the Supreme Court laid down a structured sentencing framework to ensure fairness in awarding the death penalty. The guidelines required trial courts and High Courts to conduct a detailed assessment of mitigating circumstances, including the convict’s socio-economic background, mental health, psychological condition, and potential for reform.
The Court stressed that sentencing cannot be mechanical and must be tailored to the individual circumstances of the accused. Unfortunately, this framework was not applied in Dupare’s case.
