In a significant judgment, the Supreme Court of India has set aside the death penalty of a man accused of murdering his wife and 12-year-old daughter, citing violations of his fundamental right to a fair trial under Article 21 of the Indian Constitution.

A bench comprising Justices Vikram Nath, Sanjay Karol, and Sandeep Mehta ruled in favor of the appellant, overturning the earlier verdict of the Allahabad High Court. The Court identified several irregularities in the trial that resulted in procedural unfairness, ultimately leading to the denial of justice.

The Supreme Court pointed out critical flaws in the trial process. The accused was not provided with an effective defense as his legal counsel was frequently changed, leaving him with insufficient time to prepare a strong case. Additionally, key prosecution witnesses were examined in the absence of his lawyer, depriving him of the opportunity for cross-examination.

"The frequent change of counsel and reserving the matter for judgment on the very day a new lawyer was appointed raises concerns about the adequacy of the appellant’s defense. Was his case effectively argued? Were all prosecution gaps sufficiently explored? These doubts must be addressed when imposing a death sentence," the Court observed.

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Referring to the precedent set in Anokhilal v. State of M.P. (2019), the Court underscored that merely appointing a defense counsel is not enough; the representation must be effective and meaningful. The Court further noted that the defense statements were recorded inadequately, with general questions that failed to address all incriminating circumstances.

Citing Bashira v. State of U.P., the Court emphasized the necessity of allowing sufficient time for legal counsel to prepare and argue cases, particularly in capital punishment cases.

"Capital punishment demands the highest standards of procedural fairness. The presence of a defense lawyer must not be a mere formality; their role is to ensure that justice is served," the Court stated.

International Legal Standards and the Right to Fair Trial

The Supreme Court also referred to international legal obligations under the Universal Declaration of Human Rights (UDHR) and the International Covenant on Civil and Political Rights (ICCPR), both of which guarantee fair trial rights to every accused person, regardless of the nature of their crime.

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Additionally, the Court cited the Rome Statute, which establishes international legal principles regarding an accused person's right to a fair trial:

"Even in cases involving the most heinous crimes against humanity, the accused is entitled to fundamental legal protections. The law demands a fair and just process before condemning any individual," the judgment highlighted.

Considering the severe procedural lapses and infringement of the accused’s fundamental rights, the Supreme Court overturned the death penalty and ordered a fresh trial starting from the framing of charges.

"A conviction based on flawed procedures cannot be sustained. A fair and just legal process is essential to uphold the integrity of the justice system," the Court ruled.

Case Details

• Case Title:Sovaran Singh Prajapati vs. The State of Uttar Pradesh
• Criminal Appeal Nos.: 259-260 of 2019

For the Appellant: Mr. Rajiv Shakdhar (Sr. Advocate), Mr. Aditya Verma (AOR), Ms. Shreya Rastogi, Ms. Aathma Sudhir Kumar, Ms. Sakshi Jain, Mr. Karan Khetani, Mr. Jonathan Ivan Rajan, Mr. K Rigved Prasad, Mr. Samar Singh, Ms. Parkhi Rai, Mr. Mangesh Naik.

For the Respondent: Mr. Divyesh Pratap Singh, Mr. Shashank Shekhar Singh (AOR), Mr. Ajay Singh, Mr. Abhinav Singh, Mr. Harshvardhan Visen Mall.