UNDER THE GUIDANCE OF DR. HIFAJATALI SAYYED Assistant Professor Symbiosis Law School,Hyderabad


1. LIST OF CASES…………………………………………………………………2
1.1. INTRODUCTION……………………………………………………………………….3
1.2. RESEARCH OBJECTIVE…………………………………………………………….….4
1.3. RESEARCH METHODOLOGY……………………………………………………….…4
1.4. RESEARCH QUESTIONS……………………………………………………………….5
1.5. LITERATURE REVIEW…………………………………………………………………6




5.1. SUGGESTIONS ………………………………………………………………..16
5.2. CONCLUSION………………………………………………………………….……17

6. REFERENCES…………………………………………………………… 18

Nathu Ram Godse v. The Crown (1949) CriLJ 834
Bachan Singh v. State Of Punjab (1980) 2 SCC 684
Laxmi Raj Shetty And Anr v. State Of Tamil Nadu
1988 AIR 1274

Santosh Kumar Satishbhushan Bariyar v. State of Maharashtra (2009) 6 SCC 498

Machhi Singh v. State of Punjab
1983 AIR 957
Jagmohan Singh vs State Of U.P
1973 AIR 947
Rajendra Prasad v. State of U.P 1979 AIR 916

Sher Singh v. State of Punjab 1983 AIR 465
Deena v. Union of India 1983 AIR 1155


Every society has many criminal elements which the law needs to tackle. The laws prescribe different punishments owing to the degree of the offense, starting from fines and penalties, imprisonment and fine together, imprisonment for life, and finally, the ultimate punishment that can be given to any offender, i.e., capital punishment or the death sentence. The death sentence has long been a source of contention around the world. For some, it is the most heinous and terrible penalty that remains of a barbaric human era. Others believe that the death penalty is necessary to rid society of incorrigible criminals and deter any possible offenders from committing similar offenses. Capital punishment is a significant part of the criminal justice system in India. The crimes resulting in capital punishment or the death penalty are called capital offenses or capital crimes. The term ‘Capital Punishment’ comes from the Latin word ‘Capitalis,’ meaning ‘relating to the head,’ which corresponds to the ancient form of beheading the offender as the death punishment.
So, capital punishment is a penalty sanctioned by the state against a criminal, which ensures the criminal’s death as a punishment for his offense. Capital punishment, the severest punishment, can only be given in exceptional instances of crime governed by the doctrine of ‘Rarest of Rare Cases.’ It is crucial to mention that the principle of ‘Rarest of Rare Cases’ has not been mentioned in any legal statutes or acts, but it is the result of some ideas and conventions followed by the Indian courts for a long time. There is no straight-out formula for deciding whether a case falls under the ambit of ‘Rarest of Rare Cases,’ and many essential ingredients must be kept in mind. Generally, it is based on two things: the nature of the crime and the magnitude or gravity of the crime. The Judiciary usually refrains from using capital punishment or the death penalty. Still, the courts use the death penalty as a punishment in exceptional circumstances, such as highly shocking criminal offenses.
Capital punishment is bound to be the most controversial and debated punishment. In India, there is a conundrum about capital punishment; it is neither banned nor abolished, nor do the Indian laws hold a steady perspective of the death penalty. There have been many human rights movements in India that regard capital punishment as inhuman and immoral. They consider the death penalty the most direct infringement of the Fundamental Right to Life under Article 21 of the Indian Constitution.
This paper deals with the concept of ‘Rarest of Rare Cases,’ keeping in mind both aspects, and tries to clarify the gray areas relating to this concept. The study will revolve around the foundation and fundamentals of the “Doctrine of rarest of the rare cases” and shall include detailed research analyzing case laws. The researcher will examine various provisions and concepts related to capital punishment in India. The current study has been taken up to provide in-depth knowledge of capital punishment and other related aspects associated with it.

This research aims to answer the questions regarding the concept of ‘Rarest of Rare Cases’ and clarify the related gray areas. The objectives of this study are :


The current research is based on the doctrinal method of analysis and secondary research as well. Doctrinal research means referring to and analyzing various existing legal acts and statutes. Secondary research involves studying and analyzing different researchers’ works to understand the topic better. Several journals and articles of many writers have been considered to get an unbiased perspective on the topic. Conceptual legal research has been applied in studying and analyzing legal statutes and multiple landmark cases.

Research objective
The research aims to answer some of the following questions :

The author, Nishad Patnaik, in his article, ‘On the Question of Capital Punishment,’ discusses the two main arguments in support of capital punishment, namely deterrence and retribution. He recognizes the sudden increase in death penalty judgments in India and emphasizes that two-thirds of the countries worldwide have abolished the death penalty by law or in practice. The argument of deterrence has a utilitarian basis: preventing severe crimes. The view of retribution is not concerned with reducing violent crimes but because the culprit deserves capital punishment. He also recognizes the ethical dilemma of keeping the culprit of a highly violent crime alive using a taxpayer’s money. Thus, this paper provides a great insight into the dichotomy of the two views of retribution and deterrence and the true nature and basis of punishments in general. However, the paper misses out on mentioning any information as to when to implement the death penalty.
In his book ‘Capital Punishment In India,’ Dr. Subhash Gupta focuses on capital punishment in India. He critically examines the ancient ways of punishing criminals, especially the death sentence. The book explains how the death sentence was executed in the earlier days and how it has changed with time. This book provides significant insights into the historical background of capital punishment in India. He also explores the steps taken by the British Indian Government toward uplifting or abolition of capital punishment in India. But this paper does not discuss the present scenario of capital punishment in India.
The authors Monica Sakhrani and Maharukh Adenwalla put forth a case against the retainment of the death penalty in India, not just on the moral and ethical grounds of humanity and its values but also based on the political economy of crime and punishment in their article, ‘Death Penalty: Case for Its Abolition.’ Although India retained the death penalty only to be awarded for the “rarest of rare cases” and “for special reasons,” it has not been clear what those rare cases or special reasons would be. The Court eventually explained the terms, but it was still not clearly defined what “rarest of rare cases” meant. Therefore, according to the authors, the sentence mainly depends on the ideas and social beliefs of the judge presiding over a particular case and not an objective set of criteria. Although the authors mentioned the present-day problems relating to capital punishment, they failed to provide suggestions for solving the same problem.
Clarence H. Patrick sets an objective not to establish an argument for or against the use of capital punishment. Instead, he limits himself to the analysis of different forms of capital punishment in other countries in his article, ‘The Status of Capital Punishment: A World Perspective.’ He recognizes the ancient nature of this form of punishment and mentions the recent discourse on this topic. This article provides essential information about the history of capital punishment in the world, along with the perspective of different societies on the same matter but fails to discuss it concerning Indian laws.
Nalini Rajan, in her article, ‘Is There an Ethical Basis for Capital Punishment?’, tries to rethink the question of whether capital punishment is justified or not. She says that the proponents of capital punishment usually come from a right-wing political ideology and the opposers come from a left-wing political ideology that tends to blame the system rather than the culprit. Thus, it is difficult to objectively discuss this topic because of the rift in opinions based on ideological spectrums. She then discusses the base argument for punishments which can take the form of three views- for the deterrence of crime in the future, for the rehabilitation of the culprit, or simply for retribution against the culprit. She discusses the possible causes of a crime and how it should relate to the concept of punishment for that particular crime. This article provides excellent insight into how different societies view punishment in light of these motivations. However, this article fails to discuss the topic from the viewpoint of the Judiciary.
Although many nations have laws that allow the death penalty, there is still no worldwide agreement on whether it is legal. In his article, ‘To Kill or Not To Kill: The Unending Conundrum,’ S.B. Sinha discusses how the Indian legal system has struggled to define the conditions and legitimacy of the death sentence. He explores the variations of the Bachan Singh “rarest of rare” test, how trial procedures in India are prone to errors, and the issue of prisoners who have been given the death penalty who are languishing on death row because of execution delays while providing a conceptual, historical overview of the Indian position of law. Justice S.B. Sinha explains how the Indian Judiciary has become more hesitant to impose the death penalty due to the growing emphasis on alternative sentencing options and the worldwide legal developments opposed to the death penalty. However, this article misses out on discussing the other factors and suggestions which should be kept in mind while deciding whether to give the death sentence or not.


Capital punishment is known to be one of the most ancient punishments ever in the world. There has been no country in the world where capital punishment did not exist during humanity’s history. Thus, capital punishment has been an integral part of humankind’s history. In ancient days, even petty crimes could be given the death penalty. Even minor offenses like stealing, trespassing, defying the king’s orders, fights, and other misdeeds resulted in death punishments in ancient times. There were no such written laws or codes, and primitive law was primarily oral. The punishment for all the crimes ranging from petty stealing to the most dangerous crimes like murders or war crimes, was decided only by the king.
Death penalties were given in many different forms in the ancient period. The punishment for spreading false lies, housebreaking, and stealing the king’s elephants and horses was hanging to death. According to Arthasatra, the sentence of beheading was given to criminals who committed a willful murder or stole a herd of cattle. A person plotting against the king, creating dissatisfaction in the army, and murdering his father, mother, son, brother, or ascetic was burnt alive as the punishment. Manu, the author of Manushastra, even prescribes death penalties for adultery and sexual offenses.
After a careful review of the debates in British India’s Legislative Assembly, it was found that none of the members raised any propositions for abolishing the death sentence till 1931. Shri Gaya Prasad Singh, a member of the assembly from Bihar, introduced the recommendation to abolish the death penalty under the Indian Penal Code in 1931. However, the proposal was not agreed upon by the then Home Minister, Sir John Thorne. He also explicitly mentioned the government’s policies in his debates in 1946 before the independence of India and cleared that the government never considered banning capital punishment under the IPC.
When India gained independence, it retained many of the laws made by the British government during the colonial period. These included the Indian Penal Code, 1860, and the Code of Criminal Procedure, 1898. And one of the six punishments under the Indian Penal Code was the death sentence, which continued to be part of Indian punishments. The first case that resulted in capital punishment after the independence of India was the case of Nathu Ram Godse v. The Crown . In this case, Nathu Ram Godse shot Mahatma Gandhi dead on 30th January 1948. He was then imposed with a death sentence by the Punjab High Court.
According to Section 367(5) of the CrPC , the courts needed to give the reasons for not giving the death penalty for the offenses which are by law given death punishment. But the Parliament repealed Section 367(5) of the CrPC in 1955, significantly changing the position of capital punishments in India. The courts no longer needed special reasons for not imposing the death sentence for crimes having the death sentence as the prescribed penalty. In 1956, many attempts to abolish the death penalty in India were made but could not be passed because of rejection in the Lok Sabha. Further continuous efforts were made in the Rajya Sabha as well in the years 1958 and 1962, but which was not successful either. The Law Commission of India, justice J.L Kapur headed, supported the death sentence as a punishment for severe offenses in its 35th report in 1967.
In 1973, the legislature modified the law to make it mandatory to cite specific reasons under Section 354 (3) CrPC 1973 when passing a death sentence. Now the judges had to show special reasons for imposing a death sentence on an accused.


The Indian laws neither have a leaning towards capital punishment nor do they discard it entirely, which, when put legally, is very confusing. So far, the judicial system has not called for absolute abolition; however, it has practiced partial retention by establishing rules for implementing capital punishment. The Indian Judiciary has often stated that life imprisonment is the norm and capital punishment is an exception. So the concept of ‘The Rarest of Rare Cases’ is exceptionally crucial in a country like India, where this concept describes the limitation of the death sentence.
The doctrine ‘The Rarest of Rare Cases’ was first recognized in the case of Bachan Singh v. the State Of Punjab . In this case, the appellant, Bachan Singh, had committed three murders and was given a death sentence by the session’s Court, which the High Court further confirmed. The Supreme Court decided that the crime’s gravity and extent must be considered before imposing a death sentence. They also supported the constitutionality of capital punishments and laid down the basics of the principle of ‘Rarest of Rare Cases’. The convict was given a death sentence for the murder of three persons as it came under the ambit of rare crimes.
During this case, the Supreme Court of India decided to make a doctrine precisely for the offenses culpable with the death sentence to reduce the ambiguity of courts regarding when to impose a death sentence on a criminal. Using the death sentence as a punishment was held constitutional by the Supreme Court by a 4 to 1 majority, and it was declared that capital punishments could only be given in exceptional situations, which later came to be known as ‘The Rarest of Rare Cases.’ However, the doctrine was not entirely explained, i.e., the limit to which it could be applied was not apparent. The death sentence could be used for a crime with the death penalty as an option and the general punishment as life imprisonment.
In the case of Laxmi Raj Shetty v. State of Tamil Nadu , the First Additional Sessions Judge, Madras, sentenced Laxmi Raj to death under Section 302 of the IPC for the murder of deceased P.N. Gnanasambandam. According to the prosecution, the deceased was struck on the head and then stabbed to death with a stitcher. Following a referral by the Additional Sessions Judge, the High Court upheld the appellant’s convictions and sentence.
The appellants then sought relief from the Supreme Court through an appeal. The Court considered the fact that Lakshmi had used two stitchers lying in the Bank premises instead of a weapon to assault the deceased, indicating that the murder was not pre-planned. Given the nature of the weapon used, the accused appeared to act on the spur of the moment. Given the circumstances, the Court decided that this case could not be considered a rare case and ordered that Lakshmi Raj’s death sentence be changed to life imprisonment.
In the case of Santosh Kumar Bariyar v. the State of Maharashtra in 2009, the Supreme Court of India held that the presence of ‘Rarest of Rare Cases’ is a must for imposing a death penalty on a criminal. It upheld the constitutionality of Section 354(3) and established that life imprisonment should be the general punishment while death sentence can be an exception in some cases. The Court also struck down Section 303 of the IPC that mandated the death penalty for all the criminals serving life imprisonment.
The courts must use a two-part test to determine whether the death penalty must be applied. The judge must first decide if the case was among the “rarest of the rare.” The Court must create a list of aggravating and mitigating factors in order to accomplish this. When reformation is possible, the Court must opt for life in prison as an alternative. Courts must provide evidence as to why the defendant cannot be changed or otherwise rehabilitated before passing the death sentence.

In the case of Bachan Singh v. the State Of Punjab, the Court decided that capital punishment can not be banned in India and laid down some propositions regarding the implementation of the death sentence as punishment. The following are the provisions –
i. The courts need not use the extreme step of capital punishment for previously mentioned crimes except for the offender’s extreme culpability.
ii. It was said that not only the crime but the situations of the crime were also to be analyzed before imposing the death penalty on someone.
iii. The Court made it clear that life imprisonment is the actual punishment for such cases, and capital punishment is an exception. The death sentence can only be given where life imprisonment seems insufficient for the crime committed. Machhi Singh, the primary accused in the case of Machhi Singh v. the State of Punjab , and eleven accomplices carried out raids on several villages in a single night, killing seventeen people—men, women, and children—for no apparent reason other than that they were related to one Amar Singh and his sister Piyaro Bai.
The facts of the case show that it was a cold-blooded murder committed while the victims were helpless and unprotected. The crime committed was exceptionally depraved and heinous and thus came under the ambit of the rarest of rare cases. The Supreme Court upheld the concurrent view of the Sessions Court and the High Court that appellants Machhi Singh, Kashmir Singh, and Jagir Singh should face the death penalty. As a result, the death penalty was upheld.
Though the case of Bachan Singh v. the State Of Punjab introduced the concept of ‘rarest of rare case’, it was during the Machhi Singh case that the Court set up some essential criteria for deciding whether a case fell under the category of ‘Rarest of Rare Cases’ or not. The following criteria were laid down by the Supreme Court to make it easy for other courts –
A. Way of committing the murder – When someone murders in an extremely cruel, brutal, and sinister way, it is said to be a rare crime. Such crimes generally awaken an incredible outrage and resentment in society, and thus the criminal can be imposed with a death sentence in such cases. Some examples of the same are as follows –
i. Burning a person alive is one such crime, which can be considered a rare crime. When someone’s house is set on fire to burn him alive, the criminal may be awarded a death sentence.
ii. Torturing someone to death can be classified as one rare crime. Torturing someone to kill them is inhuman, and the criminal can be imposed with a death sentence in such a case.
iii. Mutilating the body of the victim is an unthinkable act to commit. This kind of act can definitely be awarded a death sentence.
B. The motive behind the murder – When the motive behind the murder is completely materialistic and cruel, the crime can be considered rare. If the Court decides, these kinds of murders can be sentenced to capital punishment. Some examples are –
i. When a person hired by someone kills a person just for the financial reward, he can be given a death sentence.
ii. When someone cold-bloodedly murders a person to inherit his property, this can be termed a rare crime and punished with a death sentence.
C. Nature of the crime – When the so-called upper caste kills a person belonging to the backward classes, it can be classified as ‘Rarest of Rare Cases’. Dowry deaths caused due to the torture of the bride are also included in this category. These types of crimes have the option of imposing capital punishment for the offender.
D. The extent of the crime – When the magnitude of the crime is enormous, for example, if someone commits multiple murders, it can be considered rare. The death penalty is standard in such cases.
E. Considering the victim’s personality ¬- If the victim of the murder is a well-known public personality, a helpless person due to old age, a child, or a vulnerable woman, the crime is definitely classified as ‘Rarest of Rare Cases’ and the criminal can be given the capital punishment.

The Fundamental Right to Life and Liberty is guaranteed to all people by Article 21 of the Indian Constitution. Additionally, it states that no one may be deprived of their life or personal liberty unless it is done so legally. This has been legally interpreted to mean that the state may take someone’s life by passing a law if there is a fair and legal procedure. The Supreme Court has also upheld the constitutional validity of the death penalty in “rarest of rare” cases, along with the central government’s insistence that it would remain in place as a deterrent for those who pose a threat to society.
The case, Jagmohan Singh v. State of Uttar Pradesh , was the first time in India’s history that the constitutional validity of “the Doctrine of Rarest of the Rare Cases” and the death penalty was contested. .” Section 302 of the Indian Penal Code was determined to violate Articles 14, 19, and 21 of the Constitution. The Court confirmed the fact that execution was constitutional. The Court ruled that no law or statute could be enacted that would revoke any rights granted to an individual in the absence of a rational foundation and subject to public scrutiny. This is why it’s difficult to claim that execution was not an exception or necessary in public controversy. If the entire process of the trial was in accordance with the CrPC, then the execution is lawful. Then the consequences of capital punishment in line with the procedures outlined by law can’t be considered unlawful.
In the case of Rajendra Prasad v. State of Uttar Pradesh , Rajendra Prasad, was sentenced to life in prison for first-degree murder due to some family fued and was released in 1972 after serving his sentence. He brutally committed murder of a person of the same family on 25th October, 1972, just 23 days after his release.The Allahabad High Court, after reviewing the facts, sentenced him to death, but the order was challenged in the Supreme Court on the grounds that the accused is not a threat to society and that the murder occurred solely because of a personal family feud.
The sentence was commuted from the death penalty to life imprisonment. The death penalty was deemed “erroneous in principle,” but not “arbitrary or excessive.” According to Krishna Iyer, “allowing appellants to escape with the lesser punishment after they committed such intentional, cold-blooded, deliberate, and brutal murders will deprive the law of its effectiveness and result in a travesty of justice.” Justice Krishna Iyer empathetically stressed that capital punishment is a violation of articles 14, 19 and 21.
However, a year later, the Supreme Court reversed its earlier ruling in the Rajendra Prasad case by a vote of 4 to 1 in Bachan Singh v. State of Punjab. It was stated that the death penalty, as an alternative punishment for murder, is not unreasonable and does not violate articles 14, 19, or 21 of the Indian Constitution. It also enunciated the principle of awarding the death penalty only in the “rarest of rare cases.”
The three judges of the Supreme Court ruled in Sher Singh v. the State of Punjab that the death penalty is constitutionally permissible within the boundaries of the Bachan Singh rule and is therefore a valid national law. Guidelines for applying the death penalty that were published in important rulings.
The Supreme Court has similarly expressed its opinions regarding the death penalty and its constitutionality in a number of other cases. However, India has adopted the death penalty as a form of punishment time and again; Mohammed Ajmal Kasab received this punishment in the past. After much debate, politics, and discussion, the Pakistani gunman convicted in the 2008 Mumbai attacks was finally hanged on 21st November, 2012. Afzal Guru, who was convicted of participating in the 2001 Parliamentary Attacks, was executed by hanging on 9th February, 2013, following a heated political debate.
In the case of Deena v. Union of India , it was argued that hanging by a rope violated Art. 21 because it was barbaric and therefore unconstitutional under section 354(5) of the Indian Penal Code. According to the Court, section 354(5) of the IPC, which designated hanging as a form of fair execution, is constitutional because it is just and reasonable under Art. 21.
Thus it is clear that the Indian Judiciary has time and again declared the capital punishment not to be violative of the Article 21 of the Indian Constitution when the decision has been taken keeping in mind the concept of rarest of rare cases.


Some suggestions are provided below to improve understanding of the concept of ‘Rarest of Rare Cases’ and to reduce ambiguity among Indian courts regarding when to impose capital punishments:
i. Standardized rules must be formulated: Though there can not be a standard rule for implementing the death sentence, and every case has to be treated differently based on the evidence and circumstances, a consistent rule should be established that broadly defines the reasons for cases that can be classified as rarest or rare.

ii. The decision must be made prudently: While giving the sanction that is capital punishment, it is important to be kept in mind that, even though the accused has made a brutal display, there’s a possibility that shows that the person who was blamed won’t create further trouble for the public at large. The decision must be taken with great care as the fate of a human life depends on it. It must be considered that the offender may not commit this kind of offense in the future.

iii. Capital punishment should not be delayed following its declaration: In the case of Triveni Bai v. Territory of Gujarat , the Supreme Court held that the execution of capital punishment or the death penalty could not be delayed unless and until there is a reasonable ground to do so in order to ensure that the defendant can receive an appropriate preliminary. In any event, it is recommended that there should not be any delay once the death penalty has been announced. Not that the accused shouldn’t have the option to appeal, but that privilege should only be granted for a short period.

iv. The execution of a person should not be rushed: The bench should thoroughly review all relevant facts before imposing the death penalty and make sure that the decision is not made hastily. The courts should disregard public sentiments during the hearings and avoid rushing the hearings to please the public sentiments.

v. Proportionality: The execution of the death sentence must be proportionate to the crime they have committed for the penalty to be appropriate for the offense they committed. The death sentence should not be used to inculcate fear in potential offenders, operate as a deterrent, and stop them from committing such a horrible crime, and it should be used when the crime is so heinous that it deserves the death sentence.


The Doctrine Rarest of Rare Cases has a very prominent position in a country like India, where the courts are neither in complete support nor in complete opposition to capital punishment. It is a good method to help the Judiciary differentiate between crimes that deserve life imprisonment from those that deserve a death sentence for murder under Section 302 of the IPC. If the death sentence is provided in accordance with the law when the crime is rare, it is not violative of the Fundamental Right to Life under Article 21 of the Constitution. From the comprehensive study, it is clear that there is a need for capital punishment in a country like India, where the crime rate is rising daily. Hence imposing a death sentence on a criminal for committing a ‘Rarest of Rare’ crime can be said as justified and fair as it is for the benefit of the public.
In the Nirbhaya case, everyone in the country wanted the criminals of Nirbhaya’s case to be sentenced to death as quickly as possible. Those four prisoners were eventually sentenced to death as well. As a result, it has been found that the capital penalty is constitutionally valid and appropriate when used in heinous and severe instances. Furthermore, empathy should not be shown to someone who does not value the lives of others or the integrity of their own country. Although determining which crimes require capital punishment is brutal, significant crimes such as rape, terrorism, and murder should always be punished with capital punishment or the death penalty.
As we learned in this article, there isn’t a statutory standard for which cases the Rarest of Rare doctrine will be applied; the issue is raised when the Court implements capital punishment. There are instances where the accused has been found guilty of murder and rape and was awarded the death penalty. However, there are also other instances with similar scenarios and circumstances when the defendant hasn’t been given an execution. It’s difficult to pinpoint the specifics that led to different sentences.

• Nishad Patnaik, On the Question of Capital Punishment, 50 ECONOMIC AND POLITICAL WEEKLY 55, 55-61(2015).
• DR. SUBHASH C. GUPTA, CAPITAL PUNISHMENT IN INDIA, Deep & Deep Publications 1 (2000).
• Monica Sakhrani and Maharukh Adenwalla, Death Penalty: Case for Its Abolition, 40 ECONOMIC AND POLITICAL WEEKLY 1023, 1023-1026 (2005).
• Clarence H. Patrick, The Status of Capital Punishment: A World Perspective, 56 THE JOURNAL OF CRIMINAL LAW, CRIMINOLOGY, AND POLICE SCIENCE 397, 397–411(1965).
• Nalini Rajan, Is There an Ethical Basis for Capital Punishment?, 33 ECONOMIC AND POLITICAL WEEKLY 701, 701-704 (1998).
• S.B. Sinha, To Kill or Not To Kill: The Unending Conundrum, 24 NATIONAL LAW SCHOOL OF INDIA REVIEW 1, 1-29 (2012).
• DR. SUBHASH C. GUPTA, CAPITAL PUNISHMENT IN INDIA, Deep & Deep Publications 1 (2000).
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