The Machhi Singh vs State of Punjab 1983 is a landmark Supreme Court judgment that explained the doctrine of rarest of rare doctrine for the death penalty in India. It emerged from a brutal revenge attack in Punjab, where Machhi Singh and his associates killed 17 people. The Supreme Court upheld the death sentences and stressed that capital punishment should be reserved for the most heinous crimes. The case of Macchi Singh v State of Punjab set an important precedent which highlighted that the death penalty must be applied only in exceptionally grave circumstances. Learn about other important Landmark Judgements.

Machhi Singh vs State of Punjab Introduction

The landmark case Machhi Singh vs State of Punjab 1983 arose from a brutal family feud that led to the tragic murder of 17 people across five villages in a single night. It became a landmark case for the interpretation of the Supreme Court of the "rarest of rare" doctrine in awarding the death penalty under Section 302 of the Indian Penal Code.

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The case of Machhi Singh vs State of Punjab centers around a violent family feud in Punjab that resulted in the deaths of seventeen individuals across five villages during a single night in August 1977 which led to multiple trials, convictions and appeals involving Machhi Singh and his associates. The following are the brief facts of Machhi Singh v State of Punjab -

Machhi Singh vs State of Punjab Background

A violent feud erupted between two families in Punjab which led to a series of tragic events. On the night of August 12-13, 1977, seventeen people including men, women and children related to Amar Singh and his sister Piaro Bai were killed in five separate incidents. These incidents occurred in quick succession across five neighboring villages.

Prosecution

Machhi Singh, along with eleven other relatives and associates, were prosecuted in five separate sessions trials. Each trial related to the killings in one of the villages. Machhi Singh was the common accused in all trials but the other accused varied in each case.

Conviction and Sentencing

At the end of the trials, several accused were convicted. Four were sentenced to death and nine were sentenced to life imprisonment. They were also convicted for various other offences and punished accordingly.

Appeal in High Court of Punjab & Haryana

The convictions and sentences led to five murder references and fourteen appeals before the High Court of Punjab and Haryana. The High Court upheld the convictions and confirmed the death sentences.

Supreme Court Appeal

Aggrieved by the decision of the High Court of Punjab & Haryana, the convicts then filed special leave petitions to appeal before the Supreme Court after their appeals were dismissed and death sentences confirmed.

Arguments by the Defence

In Machhi Singh vs State of Punjab, the defence was represented by R.L. Kohli and R.C. Kohli, questioned the reliability of the eyewitness identification. They argued that since the murders occurred at night with only lanterns for light, the visibility was poor and identification was prone to error. Given the rural setting without electricity, they claimed that the witnesses could not have accurately identified the accused. They also contended that the conviction was largely based on circumstantial evidence which should not justify a death sentence.

Arguments by the Prosecution

The prosecution in Machhi Singh vs State of Punjab was led by Harbans Singh and D.D. Sharma, dismissed the defence’s doubts, asserted that villagers were accustomed to lantern light and could see clearly under such conditions. The accused were known in the locality which made it clear for them to be easily recognizable even in dim lighting. The Prosecution highlighted the cold-blooded and premeditated nature of the killings as aggravating factors and argued that the death penalty was justified given the extreme brutality and planning behind the murders.

Machhi Singh vs State of Punjab Issue addressed

The following issues were addressed in the case of Machhi Singh vs State of Punjab 1983 -

Scope and Application of the Death Penalty

The main issue was whether the imposition of the death sentence in cases involving multiple murders is constitutionally valid and justified under the principles laid down in Bachan Singh v. State of Punjab.

Interpretation of the "Rarest of Rare" Doctrine

The Supreme Court in Machhi Singh vs State of Punjab examined how courts should interpret and apply the “rarest of rare” standard when deciding whether the death penalty is appropriate, especially in light of the circumstances of both the crime and the offender.

Balancing Aggravating and Mitigating Circumstances

The Court in Machhi Singh vs State of Punjab also assessed whether the courts are obligated to weigh aggravating factors (like premeditated, brutal killings) against mitigating factors (such as the background or intent of the offender) before awarding the death penalty.

Benefit of Doubt Doctrine

Lastly, the Supreme Court in Machhi Singh vs State of Punjab also examined whether any doubts emerging from the evidence of the Prosecution (e.g., regarding the identification of weapons or witnesses' credibility) should entitle the accused to acquittal or reduced sentence.

In Machhi Singh vs State of Punjab case Section 300 of Indian Penal Code played a significant role. The following is the legal analysis of this provision -

Section 302 of Indian Penal Code: Punishment for Murder

Section 302 (Now Section 103 of Bharatiya Nyaya Sanhita, 2023) states that “Whoever commits murder shall be punished with death, or imprisonment for life, and shall also be liable to fine.” In Machhi Singh vs State of Punjab, the accused were charged and convicted under Section 302 Indian Penal Code for the intentional killing of 17 individuals.

Machhi Singh vs State of Punjab Judgment and Impact

On 20th July 1983, the 3-Judge Bench of the Supreme Court comprising Justice S. Murtaza Fazal Ali, Justice A. Varadarajan and Justice M. P. Thakkar in Machhi Singh vs State of Punjab reaffirmed the principles laid down in Bachan Singh vs State of Punjab regarding the imposition of the death penalty. It held that the death sentence should only be awarded in the “rarest of rare” cases, where life imprisonment is clearly inadequate considering the nature of the crime and the circumstances of the offender.

The Court in Machhi Singh vs State of Punjab highlighted that before deciding on the death penalty, the judiciary must consider a balance sheet of aggravating and mitigating circumstances, giving full weight to factors that may favor the accused. Only when the mitigating factors fail to outweigh the brutality or gravity of the crime, can death be imposed as a punishment.

The Supreme Court in Machhi Singh vs State of Punjab laid down guiding questions to determine the necessity of a death sentence:

• Is the crime so uncommon and brutal that life imprisonment is insufficient?
• Are the circumstances so extreme that no alternative remains but the death sentence, even after considering all mitigating aspects?

Applying these principles, the Supreme Court in Machhi Singh vs State of Punjab found that the premeditated mass killings by Machhi Singh and his associates, involving 17 innocent victims, constituted an exceptionally heinous act that fit within the "rarest of rare" category. The murders were not only brutal but committed with calculated intent, thereby justifying capital punishment.

Additionally, the Supreme Court rejected arguments about unreliable identification due to poor lighting, stating that people in villages often adapt to low-light conditions. The benefit of the doubt was not applicable as the overall evidence, including eyewitness accounts, was deemed reliable.

Thus, the Supreme Court in Machhi Singh vs State of Punjab upheld the death sentences of Machhi Singh and three others.

Supreme Court judgments on the death penalty in India over the years

The Supreme Court of India has consistently shaped the legal framework surrounding the death penalty through a series of landmark judgments. The following are some of the important judgements on death penalty:

Jagmohan Singh v. State of Uttar Pradesh 1973

A Constitution Bench upheld the validity of the death penalty and rejected the arguments that it violated Articles 14, 19, and 21 of the Indian Constitution due to lack of sentencing guidelines. The Supreme Court highlighted that the death sentence, when imposed through legally established procedures, does not infringe on the right to life.

Bachan Singh v. State of Punjab 1980

The Supreme Court reaffirmed the constitutionality of the death penalty under Section 302 Indian Penal Code. The Court stated it did not violate Article 19 or Article 21. Importantly, the Court introduced the “rarest of the rare” doctrine under which death should only be imposed when life imprisonment is inadequate. It highlighted the need to consider both the offence and the offender including factors like potential for reformation and the age of the offender.

Mithu v. State of Punjab 1983

The Court struck down Section 303 Indian Penal Code which mandated the death penalty for life convicts committing murder, finding it unconstitutional under Article 14 and Article 21. The Court held that the provision was arbitrary because it denied judges the discretion to consider case-specific circumstances thereby violating due process and equality.

Machhi Singh vs State of Punjab 1983

A three-judge bench in Machhi Singh vs State of Punjab elaborated on the “rarest of the rare” test by identifying five key factors: manner of commission, motive, antisocial nature of the crime, magnitude of offence and victim’s status. The judgment highlighted a careful balancing of aggravating and mitigating circumstances.

Kehar Singh v. Union of India 1988

The Court explained that the President’s and Governor’s powers under Article 72 and Article 161 to decide mercy petitions are distinct from judicial powers. Although an oral hearing may be allowed during mercy consideration, it is not a right. The courts cannot review the substance of the mercy decision but they can ensure that procedural and constitutional norms are followed.

Swamy Shraddhananda v. State of Karnataka 2008

The Court critiqued Machhi Singh vs State of Punjab case for expanding the scope of the death penalty beyond what was intended in Bachan Singh. It highlighted that the Machhi Singh v State of Punjab case categories were illustrative, not binding and must be applied with flexibility.

Santosh Kumar Bariyar v. State of Maharashtra 2009

This judgment reaffirmed that death sentences should only be awarded when life imprisonment is unquestionably inadequate. It laid down a two-step approach: 

• First, determine if the case qualifies as “rarest of the rare” by assessing aggravating and mitigating factors
• Second, impose death only if reformation and rehabilitation are ruled out, with the court having to justify this conclusion explicitly.

Shatrughan Chauhan v. Union of India 2014

The Court ruled that prolonged delays in executing death sentences due to pending mercy petitions are grounds for commuting the sentence to life imprisonment. The seriousness of the crime should not influence the decision once the delay is established.

Mukesh v. State (NCT of Delhi) 2017

The Court in Mukesh vs State of NCT of Delhi held that in cases of flawed sentencing, higher courts can either remand the matter to lower courts for proper sentencing or permit the convict to submit relevant material and arguments on sentencing at the appellate stage.

Conclusion

Machhi Singh vs State of Punjab the Supreme Court upheld the death sentences and held that the deliberate and heinous nature of the mass murders qualified as a "rarest of rare" case. The judgment clarified when capital punishment is constitutionally justified.