The Supreme Court of India upheld the conviction of Deen Dayal Tiwari for the brutal murders of his wife and four minor daughters but commuted his death sentence to life imprisonment without remission. The Court underscored the importance of prioritizing rehabilitation and reform over capital punishment, even in cases involving multiple homicides.

Case Background

The incident occurred in November 2011 in Faizabad (now Ayodhya), Uttar Pradesh. Tiwari’s brother and sister-in-law heard screams from his house late at night. Upon arriving, they found the door locked and witnessed Tiwari emerging with a blood-stained axe. Police later forced entry and discovered the bodies of his wife and four daughters, aged between 3 and 10, with fatal injuries from sharp weapons.

The trial court and Allahabad High Court convicted Tiwari under Section 302 IPC, labeling the crime as “rarest of rare” and imposing the death penalty. However, the Supreme Court reassessed the sentence, focusing on mitigating factors.

Read Also - SC: Child Born in Marriage Presumed Legitimate; DNA Test Cannot Be Forced on Adultery Allegations

The bench of Justices Vikram Nath, Sanjay Karol, and Sandeep Mehta emphasized the role of circumstantial evidence, including Tiwari’s presence at the crime scene with a blood-stained axe, the recovery of weapons such as an axe and knives from his locked room, and medical reports confirming that the injuries matched the weapons used. The defense argued gaps in forensic evidence and alleged FIR manipulation, but the Court dismissed these claims, stating minor discrepancies did not undermine the core evidence.

While acknowledging the crime’s heinous nature, the Court highlighted mitigating factors such as Tiwari’s lack of criminal history, his “satisfactory” prison conduct, and probation reports suggesting potential for reform.

“Even where multiple murders have been committed, if there is evidence or a reasonable possibility of reform, a lesser sentence must be preferred.”

The Court referenced precedents like Bachan Singh v. State of Punjab (1980), which restricts the death penalty to cases where reform is impossible. It also cited State of Uttar Pradesh v. Krishna Master (2010), where the death penalty was commuted for a family massacre due to honor disputes, and Prakash Dhawal Khairnar v. State of Maharashtra (2002), which imposed life imprisonment despite the annihilation of a brother’s family.

Read Also - Supreme Court Questions Delhi High Court’s Interim Stay on Discharge Order in Murder Case

Highlighting reformative justice, the Court stated,

“The Constitution mandates scrutiny of both the crime and the criminal. A convict’s capacity for reform cannot be ignored, even in grave cases.”

On societal impact, the judgment noted,

“While the crime shocks collective conscience, the punishment must balance societal interests with the convict’s humanity.”

Read Also - Supreme Court Reserves Judgment on PIL Seeking Inclusive e-KYC for Acid Attack Survivors and Persons with Disabilities

The ruling establishes that future cases must evaluate aggravating factors such as brutality and victim vulnerability against mitigating circumstances like age and reform potential. Courts are advised to avoid capital punishment unless rehabilitation is unequivocally impossible and to prioritize life imprisonment without remission for heinous crimes, as seen in previous rulings like Swamy Shraddananda v. State of Karnataka (2008).

While confirming Tiwari’s guilt, the Supreme Court modified his sentence to life imprisonment until natural death, barring remission. The judgment aligns with global trends toward restricting the death penalty, reaffirming India’s commitment to humane justice.

Case Title:  Deen Dayal Tiwari v. State of Uttar Pradesh (Criminal Appeal Nos. 2220-2221 of 2022)