SURESH AND ORS. v. STATE OF MADHYA PRADESH INSC 703

SURESH AND ORS. v. STATE OF MADHYA PRADESH Year Decided: 2023 Bench: Pankaj Mithal, Abhay S. Oka Suresh – Appellant State of Madhya Pradesh – Respondent

Facts: In Suresh v. State of Madhya Pradesh (2019), the appellant, Suresh, was convicted of raping and murdering a 4-year-old girl, with the prosecution relying on circumstantial evidence, including the last-seen theory, medical reports, and forensic findings. The trial court and the Madhya Pradesh High Court found him guilty and sentenced him to death, citing the "rarest of rare" doctrine. On appeal, the Supreme Court upheld the conviction but commuted the death penalty to life imprisonment without remission for 25 years, emphasizing the need to balance justice for heinous crimes with the possibility of reform. The Court also considered the appellant's socio-economic background and reiterated the principles governing the imposition of capital punishment. This judgment underscores a cautious and balanced approach to sentencing in cases involving heinous crimes.

Issue: Whether the death penalty was justified in a circumstantial evidence-based conviction for the rape and murder of a minor?

Decision: The Supreme Court upheld Suresh's conviction for the rape and murder of a minor but commuted the death penalty to life imprisonment without remission for 25 years, emphasizing the need to balance justice with the possibility of reform.

Legal Reasoning: The Supreme Court's reasoning was based on its principles for sentencing, as well as circumstantial evidence. It confirmed the conviction because the evidence presented to it was a complete chain which led the appellant beyond reasonable doubt to be involved in the crime. However, while considering the death sentence, the Court placed importance on the "rarest of rare" doctrine established in *Bachan Singh v. State of Punjab*. The Court considered socio-economic background, possibility of reform, and proportionality while evaluating the punishment. In its opinion, the court put forth that though the crime was despicable, life imprisonment without remission for 25 years would be an apt punishment to reap a balance of retributive justice with rehabilitation. This judgment highlighted that the death penalty should be given only in cases where no alternative punishment is adequate. The judgment once again emphasized judicial discretion in capital sentencing.