Acid Attack and Sentencing: Supreme Court Modifies Death Penalty in Yogendra Singh Case

The case of Yogendra @ Jogendra Singh vs. State of Madhya Pradesh involved a horrific acid attack that led to the tragic death of a woman, along with grievous injuries to multiple family members. This judgment by the Supreme Court of India reviewed the Madhya Pradesh High Court’s decision, which had upheld the death sentence awarded by the Sessions Court. However, the Supreme Court ultimately modified the death penalty to life imprisonment.

The case highlights the legal principles guiding sentencing in cases of extreme brutality. It also demonstrates how courts interpret the ‘rarest of rare’ doctrine when deciding whether a death sentence is justified.

Background of the Case

The appellant, Yogendra Singh, was accused of pouring acid on a woman named Ruby, which led to her death. The attack also severely injured her grandmother, nephew, and brother. The Sessions Court convicted the appellant under Sections 302 (murder), 326(A) (causing grievous hurt by acid attack), and 460 (trespass) of the Indian Penal Code (IPC). He was sentenced to death for murder, life imprisonment for the acid attack, and rigorous imprisonment for ten years for other offenses. The Madhya Pradesh High Court confirmed the death sentence.

Incident Details

Ruby was married to one Sanjay Gupta and had two children. The appellant had developed an infatuation with her and allegedly harassed her. Due to ongoing marital discord caused by suspicions of an affair, Ruby left her marital home and started living with her maternal uncle. The appellant, enraged by the rejection, threatened her father (PW 8) and demanded that she return.

On the night of the attack, the appellant trespassed into Ruby’s home while she and her family were asleep. He confronted her and declared, “Though she doesn’t want to live with him, he is not going to let her live with anybody else.” He then threw acid on her, causing extensive burns covering 90% of her body. When other family members attempted to intervene, the appellant threw acid on them as well, leaving multiple victims with severe injuries.

Key Arguments by the Appellant

The appellant challenged his conviction and death sentence on the following grounds:

• The conviction was primarily based on the dying declaration of the deceased, which he argued was unreliable.
• His intent was to disfigure, not to kill; hence, the charge of murder was not applicable.
• His prior criminal record should not influence sentencing, as the previous case was unrelated.
• The case did not qualify as a ‘rarest of rare’ case requiring the death penalty.

Arguments by the Respondent

The State of Madhya Pradesh argued in favor of upholding the death sentence:

• The dying declaration was recorded by an executive magistrate and corroborated by multiple eyewitnesses.
• The appellant was a habitual offender and had been out on bail for another murder case.
• The crime was deliberate, premeditated, and executed with extreme cruelty.
• The appellant’s actions not only killed the deceased but permanently scarred the other victims, justifying the harshest punishment.

Supreme Court’s Observations

The Supreme Court found the evidence against the appellant irrefutable. The judgment stated:

“All the circumstances of the case and particularly the dying declaration of Smt. Ruby, unerringly point to the Appellant as the one who caused her death.”

The Court also noted the importance of the forensic evidence, including fingerprint analysis, which matched the appellant’s prints on the acid bottle found at the scene.

The ‘Rarest of Rare’ Doctrine

To determine whether the death penalty was warranted, the Court examined the principles laid down in Bachan Singh vs. State of Punjab, which emphasize that capital punishment should be reserved for only the most exceptional cases.

The Court stated:

“There are numerous other circumstances justifying the passing of the lighter sentence; as there are countervailing circumstances of aggravation.”

In Machhi Singh vs. State of Punjab, the Supreme Court provided a framework for deciding when a case qualifies as the ‘rarest of rare.’ The Court applied these guidelines and noted:

• The act was undoubtedly heinous but lacked prolonged torture or extreme depravity.
• The appellant’s previous criminal record, while serious, did not establish a pattern of indiscriminate violence.
• The choice of acid as a weapon suggested an intent to cause grievous harm, rather than certain death.

Final Judgment

The Supreme Court modified the death sentence to life imprisonment, stating:

“There is no particular depravity or brutality in the acts of the Appellant that warrants a classification of this case as ‘rarest of the rare’.”

The Court concluded that while the crime was reprehensible, it did not meet the threshold for capital punishment.

Impact of the Judgment

This case reinforces the legal principles guiding capital punishment in India. It underscores the necessity of differentiating between cases that warrant the death penalty and those where life imprisonment is a more appropriate sentence. The ruling also sets a precedent for evaluating acid attack cases under the lens of premeditation, intent, and brutality.

Conclusion

The Supreme Court’s verdict in this case serves as a critical reference for future acid attack trials. It upholds the principles of justice by ensuring proportionate punishment while maintaining the deterrent effect of strict sentencing. This case highlights the importance of judicial discretion in capital punishment and the significance of the ‘rarest of rare’ doctrine in safeguarding justice.

Petitioner Name: Yogendra @ Jogendra Singh.
Respondent Name: State of Madhya Pradesh.
Judgment By: Justice S.A. Bobde, Justice L. Nageswara Rao, Justice R. Subhash Reddy.
Place Of Incident: Madhya Pradesh.
Judgment Date: 17-01-2019.

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