SC: Lack of Criminal Antecedents Not Sole Reason for ‘Rarest of Rare’ Cases

In a recent ruling, the Supreme Court of India delivered a landmark judgement that addresses the criteria used to determine ‘rarest of rare’ cases and the power of Constitutional courts to modify sentences. This decision holds significant implications for the judicial system and underscores the need for adaptability in criminal cases.

The Court’s ruling establishes that lack of criminal antecedents alone cannot be the sole criterion for categorising a case and paves the way for the imposition of specific minimum terms for life imprisonment. In this article, we delve into the details of this ruling and its broader implications.

Constitutional Courts’ Authority to Amend Sentences

The recent ruling by the Supreme Court affirmed that Constitutional courts possess the authority to modify sentences of life imprisonment, even in cases where the trial court has not imposed the death penalty. This groundbreaking decision empowers the higher judiciary to determine a definite period of incarceration by establishing a minimum term, such as 20 or 30 years. 

A Shift in Categorization Criteria

The Supreme Court bench, composed of Justices Abhay S Oka and Rajesh Bindal, emphasised that an accused’s lack of prior criminal record cannot be the sole basis for categorising a case. The Court stressed the importance of assessing the possibility of reformation while taking into account the impact of overly lenient sentencing in brutal cases on public confidence in the legal system. 

The Authority to Modify Life Imprisonment Sentences

One of the crucial aspects of the Supreme Court’s ruling is the clarification that Constitutional courts have the authority to modify a life imprisonment sentence by including a minimum term, even when the trial court has not imposed the death penalty.

This discretion allows the courts to consider the gravity of the offence, the potential for reformation, and other relevant factors in imposing a fair and just sentence. By providing this clarification, the Supreme Court ensures that the power to modify sentences is not limited to cases where the death penalty is involved.

Case Background: Rape and Murder Conviction

The judgment was delivered in an appeal filed by a convict who had been sentenced to life imprisonment for the heinous crimes of rape and murder. The appellant was found guilty of murdering a woman employed in an IT firm in Bengaluru. The unfortunate incident occurred when the victim utilised the appellant’s vehicle for transportation from her office to her home during the early hours of the morning.

Considerations for Sentencing

In this particular case, the Supreme Court focused solely on the issue of the sentence. The appellant’s counsel argued that at the time of the offence, the convict was only 22 years old and had since established a family, comprising a young wife, child, and elderly parents. 

The Power of Constitutional Courts

The State government’s counsel contended that Constitutional courts possess the authority to impose modified sentences, considering the gravity of the offence, even in cases where the death penalty has not been imposed.

The Supreme Court relied on various legal precedents to establish that Constitutional courts are not restricted from modifying sentences in cases without the death penalty. The Court clarified that when a case falls short of being categorised as the “rarest of rare” but still warrants a substantial sentence based on the gravity of the offence and other relevant factors, a fixed-term sentence can be imposed.

Acknowledging the Context: IT Hubs and Night Shifts

Recognizing the significance of IT hubs, particularly in leading cities like Bengaluru, often referred to as the Silicon Valley of India, the Court acknowledged the presence of night shift work and the substantial number of women employed in such companies. 

The Court’s Verdict and Modified Sentence

Based on the severity of the offence and the imperative to protect society, the Supreme Court deemed the case in question deserving of a fixed-term sentence of thirty years. Consequently, the appeal was partly allowed, and the modified sentence was granted. The appellant was represented by a team of advocates, and the Karnataka government was represented by its own legal counsel throughout the proceedings.

Conclusion

The recent ruling by the Supreme Court of India emphasises that lack of criminal antecedents is not the sole criterion for categorising cases as ‘rarest of rare.’ The decision empowers Constitutional courts to modify life imprisonment sentences by imposing specific minimum terms, even in the absence of the death penalty.

This landmark judgement highlights the judiciary’s commitment to adapting to evolving dynamics in criminal cases and ensures a fair and proportionate sentencing framework that considers the interests of justice.