Supreme Court Overturns Death Penalty in Uttar Pradesh Double Murder Case
The case of Sovaran Singh Prajapati vs. State of Uttar Pradesh is a significant ruling by the Supreme Court that highlights the necessity of a fair trial. The case revolved around a brutal double murder where the accused was convicted and sentenced to death. However, the Supreme Court overturned both the conviction and the sentence, citing major lapses in trial proceedings.
Background of the Case
On the night of June 29-30, 2014, Sovaran Singh Prajapati allegedly returned home intoxicated and got into a dispute with his wife, Mamta. He is accused of physically assaulting her and later killing both Mamta and their 12-year-old daughter, Sapna. The prosecution claimed that he first slapped his father during an argument and later demanded money from his wife for more alcohol. When she refused, he allegedly killed her and then murdered his daughter.
Following this, an FIR was registered under Section 302 of the IPC at Police Station Karhal, District Mainpuri. The case proceeded to trial, where the Sessions Court convicted the accused and sentenced him to death. The High Court of Judicature at Allahabad upheld this sentence. However, the Supreme Court found serious procedural errors and overturned the conviction.
Legal Proceedings
Trial Court Judgment
- The Additional Sessions Judge, Mainpuri, found Sovaran Singh guilty of double murder.
- He was sentenced to death under Section 302 of the IPC and given a seven-year imprisonment term for tampering with evidence under Section 201.
- The court justified the death sentence based on aggravating factors, citing the gruesomeness of the crime.
High Court Judgment
- The Allahabad High Court confirmed the conviction and death sentence.
- The court emphasized that the nature of the crime justified the extreme penalty.
Supreme Court’s Observations
Issues Identified in the Trial
The Supreme Court identified several critical errors in the trial process:
- The defense counsel was absent during crucial stages, including the examination of key witnesses.
- The accused was not adequately represented, as multiple changes in legal representation occurred.
- The cross-examination of prosecution witnesses was denied due to procedural lapses.
- The statement of the accused under Section 313 Cr.P.C. was improperly recorded.
- The trial court did not ensure the accused received proper legal aid, despite it being a capital punishment case.
Fair Trial and Legal Aid
The Supreme Court cited several judgments emphasizing the need for fair trials:
“The assurance of a fair trial is the first imperative of the dispensation of justice. It is not merely a procedure but a fundamental right of the accused under Article 21 of the Constitution.”
The court noted that the legal aid provided to the accused was inadequate. Frequent changes in legal representation deprived him of a proper defense. The court also pointed out that trials must ensure fairness for both the prosecution and the accused.
Defects in Prosecution and Defense
The Supreme Court observed that the prosecutor failed to highlight procedural irregularities. The court noted that the prosecutor should have raised objections when key witnesses were examined in the absence of defense counsel. The ruling emphasized:
“The prosecution is expected to be fair and just. It must not pursue a conviction at all costs but ensure that justice is served.”
The defense counsel also failed to provide effective representation. The accused’s lawyer was absent at critical stages, and the newly appointed counsel had insufficient time to prepare.
Supreme Court Ruling
Based on the identified trial irregularities, the Supreme Court ruled:
- The conviction and death sentence were overturned.
- The case was remanded to the trial court for a fresh trial.
- The accused would receive proper legal representation, with legal aid to be monitored.
- The trial must be expedited and conducted fairly.
The court emphasized that capital punishment cases demand the highest standards of judicial scrutiny:
“A sentence of death should not be imposed when procedural irregularities call into question the fairness of the trial. The judicial system must protect the rights of every accused, even in the gravest crimes.”
Key Takeaways
- Right to a Fair Trial: The case reaffirms that every accused is entitled to an impartial trial.
- Legal Representation: The ruling underscores the need for competent legal aid, particularly in capital punishment cases.
- Prosecutor’s Role: The decision highlights the prosecutor’s duty to ensure justice, not just secure convictions.
- Judicial Oversight: Courts must actively ensure that trials are conducted fairly, especially in cases involving the death penalty.
Conclusion
The Supreme Court’s decision in this case serves as a landmark ruling for fair trial rights. By overturning the conviction and ordering a retrial, the court reaffirmed the principle that justice must not only be done but must also be seen to be done. The case underscores the critical role of due process in criminal trials and serves as a precedent for ensuring procedural fairness in all cases, particularly those involving the death penalty.
Petitioner Name: Sovaran Singh Prajapati.Respondent Name: State of Uttar Pradesh.Judgment By: Justice Vikram Nath, Justice Sanjay Karol, Justice Sandeep Mehta.Place Of Incident: Mainpuri, Uttar Pradesh.Judgment Date: 03-02-2025.
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