Supreme Court Upholds Death Penalty in Child Sacrifice Case: A Landmark Judgment on Criminal Justice

The gruesome case of the brutal murder of a two-year-old child, Chirag Rajput, and the subsequent legal proceedings culminating in the Supreme Court’s decision has shed light on the severity of criminal justice in cases involving extreme brutality. The case involved multiple accused, including self-proclaimed tantriks, who were found guilty of sacrificing a child as part of black magic rituals. The Supreme Court upheld the death penalty for the two main accused, Ishwari Lal Yadav and Kiran Bai, marking it as one of the ‘rarest of rare’ cases.

Background of the Case

The horrific incident occurred on November 23, 2010, in Chhattisgarh, where a young child, Chirag Rajput, was kidnapped and brutally murdered. The prosecution argued that the main accused, Ishwari Lal Yadav and Kiran Bai, practiced tantrik rituals and believed that human sacrifice would bring them supernatural powers. According to the prosecution’s case, they conspired with their followers to abduct and kill the child in their house as an offering to attain ‘siddhi’ (supernatural power).

Key Legal Issues

• Whether the confessional statements made by the accused were admissible under the Indian Evidence Act.
• To what extent the circumstantial evidence corroborated the prosecution’s case.
• Whether the death penalty was justified in the given circumstances.

Petitioner’s Arguments

The counsel for the accused contended that there was no direct evidence linking them to the murder of Chirag Rajput. It was argued that the conviction was based on extra-judicial confessions, which are inherently weak pieces of evidence. Additionally, it was pointed out that there were inconsistencies in the testimonies of witnesses, and no forensic evidence conclusively proved that the recovered remains were of the victim. The defense also highlighted that the application of Section 106 of the Indian Evidence Act (which shifts the burden of proof on the accused to explain circumstances within their knowledge) was unwarranted in this case.

Respondent’s Arguments

The prosecution argued that the crime was committed in a planned and premeditated manner, making it one of the rarest of rare cases warranting the death penalty. The prosecution highlighted that multiple independent witnesses corroborated the sequence of events, and the body of the victim was recovered from the accused’s house. The trial court and the High Court had already found the accused guilty beyond a reasonable doubt. It was also pointed out that the accused had committed a similar crime in the past, where they sacrificed another child, further reinforcing the argument for awarding capital punishment.

Supreme Court’s Observations

The Supreme Court examined the evidence, witness statements, and legal precedents in detail before delivering its judgment. The Court noted:

“A prima facie case does not mean a case proved to the hilt, but a case which can be said to be established if the evidence, which is led in support of the same, were believed.”

The Court also upheld the application of Section 106 of the Indian Evidence Act, stating that since the crime occurred inside the accused’s house, they had the onus to explain how the victim’s body was found buried there.

Death Penalty: A Justified Sentence?

The Supreme Court applied the ‘rarest of rare’ doctrine to determine whether the death penalty was appropriate. The Court reiterated the principles laid down in past judgments, including Bachan Singh v. State of Punjab and Machhi Singh v. State of Punjab, where it was held that death sentences should be awarded only when life imprisonment is insufficient to meet the ends of justice.

In its ruling, the Court emphasized:

“When the murder is committed in an extremely brutal, grotesque, diabolical, revolting or dastardly manner so as to arouse intense and extreme indignation of the community, it warrants the imposition of the death penalty.”

The Court also considered the fact that the accused had previously committed a similar offense and showed no remorse, making the possibility of reform highly unlikely. Consequently, it upheld the death sentence awarded by the High Court.

Key Takeaways from the Judgment

• The ruling reinforced that extra-judicial confessions, when corroborated by circumstantial evidence, could be relied upon for conviction.
• The burden of proof could shift to the accused under Section 106 of the Indian Evidence Act when the facts fall within their exclusive knowledge.
• In cases involving extreme brutality, the death penalty remains a viable option when life imprisonment is inadequate to meet the ends of justice.

Conclusion

The Supreme Court’s decision in this case sets a significant precedent for handling cases involving brutal and ritualistic killings. It reaffirms the judiciary’s stance on capital punishment, ensuring that those who commit heinous crimes do not escape the most severe penalty. The ruling serves as a reminder that the law will take its course, even in cases where religious or superstitious beliefs are used as a cover for committing inhumane acts.

Petitioner Name: Ishwari Lal Yadav.
Respondent Name: State of Chhattisgarh.
Judgment By: Justice R. Subhash Reddy, Justice Rohinton Fali Nariman, Justice Surya Kant.
Place Of Incident: Chhattisgarh.
Judgment Date: 03-10-2019.

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