Featured image for Supreme Court Judgment dated 14-11-2018 in case of petitioner name Prahlad vs State of Rajasthan
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Supreme Court Reduces Death Sentence to Life Imprisonment in Rajasthan Minor’s Murder Case

The case revolves around the tragic incident where a minor girl, aged about 8 years, was taken from her home under the pretext of buying chocolates and was later found murdered. The accused, known to the victim’s family, was convicted under Section 302 IPC and Sections 3 and 4 of the Protection of Children from Sexual Offences Act (POCSO Act) by the Trial Court and sentenced to death.

Petitioner’s Argument:

The petitioner’s counsel argued that the case was based solely on circumstantial evidence, and the prosecution failed to establish a direct link between the accused and the crime. They contended that the chain of circumstances was incomplete and that the accused was entitled to acquittal. Additionally, they challenged the imposition of the death penalty, asserting that it was not a ‘rarest of rare’ case.

Respondent’s Argument:

The State defended the convictions, emphasizing the testimonies of witnesses who last saw the victim with the accused. They argued that the circumstantial evidence was strong enough to uphold the conviction and that the death penalty was justified given the gravity of the crime.

Supreme Court’s Judgment:

The Supreme Court meticulously examined the evidence and found that while the prosecution successfully established the accused’s involvement in the murder under Section 302 IPC, there was insufficient proof to sustain the conviction under the POCSO Act. The medical evidence did not support the charge of penetrative sexual assault, leading the court to extend the benefit of doubt to the accused regarding that charge.

The court also deliberated on whether the case fell under the ‘rarest of rare’ category warranting the death penalty. It considered factors such as the accused’s young age, absence of prior criminal records, and the lack of extreme brutality in the murder. The court ultimately concluded that life imprisonment was a more appropriate punishment.

Important Judicial Observations:

The court reiterated the principle laid down in Bachan Singh v. State of Punjab, emphasizing that the death penalty should only be imposed when there is no possibility of reform. The judgment noted:

“A real and abiding concern for the dignity of human life postulates resistance to taking a life through law’s instrumentality. That ought not to be done save in the rarest of rare cases when the alternative option is unquestionably foreclosed.”

Final Judgment:

The Supreme Court set aside the death penalty, sentencing the accused to life imprisonment while maintaining his conviction under Section 302 IPC. However, the court acquitted the accused of charges under the POCSO Act due to lack of conclusive evidence.


Petitioner Name: Prahlad.
Respondent Name: State of Rajasthan.
Judgment By: Justice N. V. Ramana, Justice Mohan M. Shantanagoudar, Justice Mukeshkumar Rasikbhai Shah.
Place Of Incident: Rajasthan.
Judgment Date: 14-11-2018.

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