Deen Dayal Tiwari vs State Of Uttar Pradesh 2025 INSC 111 - Death Sentence Commuted

Death Sentence - The imposition of capital punishment is an exception and not the rule. Even where multiple murders have been committed, if there is evidence or at least a reasonable possibility of reform, a lesser sentence must be preferred - In this case, the Appellant was convicted for the murders of his wife and four minor daughters -While commuting death sentence, SC observed: We must scrutinize not only the nature of the offence but also the totality of the offender’s circumstances - While the offence is undoubtedly brutal, certain mitigating factors, especially the Appellant’s lack of criminal antecedents and his reported conduct in prison, tilt the scales in favour of commutation. There is no material demonstrating that he would remain a perpetual threat to society or that he is beyond reform. Indeed, the Probation Officer’s input and the Superintendent of District Jail’s report show a potentially reformable individual- while the crime is heinous and deserves the highest degree of condemnation, it does not meet the threshold of “the rarest of rare” so as to irrevocably foreclose the option of life imprisonment- IPC, we consider it appropriate to commute the death sentence to one of life imprisonment till his last breath. (Para 21)

Constitution of India - Article 136 - while exercising its appellate jurisdiction under Article 136 of the Constitution of India, SC possesses the authority to scrutinize not only the conviction of an accused but also the appropriateness of the sentence imposed. (Para 23)

Sentencing - The alternate punishment for offences punishable by death, such as imprisonment for a specific term exceeding 14 years or until the natural life of the convict, remains within the judicial conscience of this Court and the High Court. (Para 23)