The Supreme Court of India recently commuted the death sentence of a man convicted for murdering his two minor children, sentencing him to life imprisonment without remission. The decision was based on key mitigating factors such as the absence of prior criminal records and other circumstances favoring leniency.
Case Background
The appellant, a bank manager, was convicted of murdering his 10-year-old son and 3.5-year-old daughter by drowning them in a water tank. The tragic incident was triggered by a long-standing dispute regarding his sister-in-law’s relationship choices. Enraged by his wife’s refusal to intervene, he killed his sister-in-law and mother-in-law before taking the lives of his own children.
Aggrieved by the High Court’s decision to uphold the death penalty, the accused approached the Supreme Court, arguing that the lower courts failed to adequately consider mitigating factors in his favor.
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The bench, comprising Justices Vikram Nath, Sanjay Karol, and Sandeep Mehta, reviewed the case in light of the well-established principle that the death penalty should only be imposed in the "rarest of rare" cases.
"We direct that the hangman’s noose be taken off the appellant-convict’s neck, and instead that he remains in prison till the end of his days given by God Almighty." – Supreme Court
While acknowledging the heinous nature of the crime, the Court emphasized that sentencing must be based on a holistic assessment of all aggravating and mitigating factors. The following reasons were key in the commutation of the death sentence:
Lack of Criminal Antecedents: The appellant had no prior criminal history.
Good Behavior in Custody: Witness testimonies highlighted his decent behavior before and after the incident.
Possibility of Reformation: The appellant expressed willingness to serve elderly inmates as a form of repentance.
The Court relied on previous landmark judgments, such as:
- Swamy Shraddananda (2) v. State of Karnataka (2008) 13 SCC 767 – Where the death penalty was commuted to life imprisonment till the convict’s natural end.
- Deen Dayal Tiwari v. State of U.P. (2025 SCC OnLine SC 237) – Highlighting the significance of absence of criminal antecedents in sentence commutation.
Balancing Justice and Mercy
While the Supreme Court did not condone the brutality of the act, it reiterated the importance of ensuring fairness in sentencing. The judgment emphasized the need to assess whether a convict is beyond reformation before imposing the death penalty.
"Live and let live" – The Supreme Court quoted this well-known proverb, stressing the importance of accepting others' personal choices.
The Court partly allowed the appeal, modifying the sentence from the death penalty to life imprisonment without remission. The appellant will now serve the remainder of his life behind bars.
Case Title: RAMESH A. NAIKA VERSUS THE REGISTRAR GENERAL, HIGH COURT OF KARNATAKA ETC.
