Vasanta Sampat Dupare vs Union of India 2025 INSC 1043 - Art.32 Constitution -Reopening Death Sentence Cases

Constitution of India - Article 32 -Death-sentence cases stand apart because the punishment extinguishes the right to life in an irreversible way, and that singular feature obliges this Court to keep the door of constitutional review open even after the ordinary appellate and review avenues have closed. Article 32 of the Constitution of India, therefore, remains available whenever a supervening fact, such as inordinate delay, emergent mental illness, or a parity-based anomaly, or a subsequently recognised procedural guarantee throws the legitimacy of a capital sentence into doubt. (Para 17)-  Article 32 empowers Supreme Court in cases related to capital punishment to reopen the sentencing stage where the accused has been condemned to death penalty without ensuring that the guidelines mandated in Manoj [ time-bound guidelines obliging Trial Courts and the State to place extensive mitigation circumstances on record including psychiatric, psychological, social-history and jail- conduct reports] were followed -Reopening will be reserved only for those cases where there is a clear, specific breach of the new procedural safeguards as these breaches are so serious that, if left uncorrected, they would undermine the accused person’s basic rights to life, dignity and fair process. (Para 31-32)

Constitution of India - Article 32 - Article 32 of the Constitution of India is not restricted to reviewing decisions of subordinate courts or executive authorities. In exceptional situations it empowers this Court to revisit even its own final orders where doing so is necessary to prevent a continuing breach of fundamental rights. The controlling test is whether such intervention is required to avert manifest injustice under Articles 14 and 21 of the Constitution of India, and technical rules of procedure cannot be permitted to thwart that constitutional mission. (Para 25) Article 32 has pride of place - a Jewel on the Crown of the Justice Delivery System - in the Indian Constitutional scheme. (Para 58)

Constitution of India - Article 14,21 -The right to be sentenced in a principled and individualized manner flows directly from Articles 14 and 21. (Para 21) The machinery which feeds the death-penalty system is itself fragile. Investigations often rely on confessions extracted in opacity, recoveries whose provenance is contested and forensic material of doubtful rigour. When such evidence is filtered through an overburdened trial process, the possibility of wrongful conviction can never be dismissed as a remote abstraction. An irreversible penalty grafted onto a fallible process endangers the very core of Article 21 of the Constitution of India. (Para 28) Until safeguards laid down in Manoj Case are fully applied, carrying out a death sentence would sit contrary to Articles 14 and 21 of the Constitution of India as they promise equality and fair procedure to every person in our society. The process leading to a death sentence must itself be beyond reproach as it must also be open, thorough and fair. (Para 29)

Sentencing -Every person, even one who has done great wrong, still carries a basic human dignity. This belief does not excuse crime but it simply means the State should keep open, wherever possible, the chance for an offender to change. It is our belief that moving from pure retribution to genuine reform is not an act of undue leniency but it is a statement of faith in the human capacity for improvement. (Para 28)

Quotes : The majesty of our Constitution lies not in the might of the State but in its restraint. (Para 1)

Precedents - when a previous decision is overruled, it means the earlier rule was never truly the law, and all actions taken based on that supposed rule are subject to the new, correct legal determination, except in cases that are already finally decided (res judicata) or where accounts have already been settled. Thus, overruling a decision has a retrospective effect, clarifying what the law always was, with limited exceptions. (Para 46)

Interpretation of Statutes - Reference to Constitutional Assembly debates can be made in the interpretation of a constitutional provision. (Para 56)