Machhi Singh vs. State of Punjab (1983)

CITATION	1. Indian Penal Code, 18600 (IPC) Section 302 – Punishment for murder Section 149 – Every member of unlawful assembly guilty of offence committed in prosecution of common objectSection 148 – Rioting, armed with a deadly weaponSection 147 – Punishment for riotingSection 34 – Acts done by several persons in furtherance of common intention2. Code of Criminal Procedure, 1973 (CrPC)Section 354(3) – Requires courts to record special reasons for awarding death sentence instead of life imprisonmentSection 235(2) – Accused’s right to be heard on the question of sentence
YEAR OF JUDGMENT	20 July 1983
PETITIONER	Machhi Singh and Others
RESPONDENT	State of Punjab
STATUTES REFERRED IN THIS CASE	M.P. Thakkar, Syed Murtaza Fazalali, FazalaliVaradarajan
BENCH	M.P. ThakkarSyed Murtaza FazalaliVaradarajan

INTRODUCTION

The case of Machhi Singh v. State of Punjab (1983) stands as a landmark judgement by the Supreme Court of India that decisively addresses the application of the death penalty under the “rarest of rare” doctrine. Originating from a brutal massacre in Punjab, this case involved Machhi Singh and his accomplices as they engaged in coordinated killings fuelled by a long-standing family feud. This judgement is critical as it establishes clear guidelines for imposing the death penalty, enhancing the principles first articulated in Bachan Singh v. State of Punjab (1980). The Supreme Court underscored the necessity of rigorously balancing aggravating and mitigating circumstances when considering capital punishment. This ruling has fundamentally shaped India’s criminal jurisprudence concerning the death penalty, reinforcing the legal framework governing such serious matters.

FACTS OF THE CASE

The appellants, Machhi Singh and others, were involved in a series of brutal killings that occurred in five villages in Punjab on the night of August 12, 1977. These attacks were carried out in a premeditated and coordinated manner as an act of revenge stemming from an earlier family feud between Machhi Singh’s family and another family. As a result of these attacks, 17 people, including women and children, lost their lives.

The Sessions Court convicted Machhi Singh and the others under various sections of the Indian Penal Code, including Section 302 (murder), and sentenced them to death. Unsatisfied with the court’s decision, the appellants filed an appeal with the Punjab and Haryana High Court, which upheld the conviction and sentence.

Subsequently, the appellants challenged the judgement in the Supreme Court of India. The main issue raised was whether the death penalty imposed was justified under the “rarest of rare” doctrine, as established in the earlier case of Bachan Singh vs State of Punjab (1980).

ISSUE RAISED

1. Was the death sentence imposed on Machhi Singh and others justified under the “rarest of rare cases” doctrine established in Bachan Singh v. State of Punjab (1980)?

2. Do the series of murders committed by Machhi Singh and his associates, as part of a premeditated plan across different villages, meet the criteria for capital punishment under Section 302 of the Indian Penal Code (IPC)?

3. Does the “rarest of rare” doctrine, as established in Bachan Singh v. State of Punjab (1980), justify the imposition of the death penalty in this case?

4. What are the guidelines for awarding the death penalty, and how should courts balance aggravating and mitigating circumstances?

5. Do the brutal multiple murders committed by the accused qualify as crimes that warrant the death penalty?

6. How should judicial discretion be exercised in sentencing to ensure consistency and fairness in capital punishment cases?

7. Whether the nature and gravity of the crime necessitate the death penalty to uphold the collective conscience of society.

REASONING

1. The court stated that life imprisonment should be the standard punishment, with the death penalty reserved for exceptionally rare cases.

2. The court explained that the death penalty may only be imposed when a crime is so shocking and cruel that society cannot tolerate it.

3. The court outlined several key points to determine if a case qualifies as “rarest of rare”, that are, “Manner of the Murder: If the murder was carried out in an extremely cruel and horrifying way (e.g., dismembering victims, burning them alive),

“Motive Behind the Murder” If the motive reveals that the criminal is particularly dangerous (e.g., committing the murder out of revenge, a desire for power, or to instil fear), “Number of Victims” If multiple people were killed at once (e.g., an entire family or a group of individuals),

 “Vulnerability of the Victim”: If the victim was particularly weak or helpless (e.g., a child, a woman, or an elderly person).

4. If the crime is so egregious that it shocks society as a whole and instills fear among the public, the court may consider imposing the death penalty.

5. Before deciding on a death sentence, the court must consider whether the criminal has the potential for rehabilitation and could become a better person. If there is a chance for improvement, then the death penalty should not be imposed.

JUDGEMENT

Upon appeal, the Supreme Court upheld the death sentences for Machhi Singh and the others, emphasising the heinous nature of the crimes and the helplessness of the victims. The Court applied the “rarest of rare” doctrine, considering factors such as the manner of the crime, the motive, and the magnitude of the offences. The judgement reinforced the notion that the death penalty is warranted in cases where the collective conscience of society is so shocked that it expects the judiciary to impose the ultimate punishment.

This decision has since become a cornerstone in the Indian judiciary’s approach to capital punishment, providing a structured framework for courts to determine the appropriateness of the death sentence in individual cases.

ANALYSIS

The Court outlined specific categories to evaluate the seriousness of a crime:

1. Crimes committed in an extremely brutal, grotesque, diabolical, or revolting manner that provoke strong outrage within the community.

2. Offences driven by motives that demonstrate total depravity and meanness, such as those fuelled by extreme greed or revenge.

3. Crimes that elicit social outrage, particularly those targeting marginalised communities or involving practices such as dowry deaths.

4. Cases involving multiple murders within a family or a large number of victims from a specific community or locality.

5. Murders of vulnerable individuals, such as children, defenceless women, or those weakened by age or infirmity, especially when the perpetrator holds a position of power or trust.

CONCLUSION

The Supreme Court’s judgement in Machhi Singh v. State of Punjab (1983) is a landmark decision that further defined the “rarest of rare” doctrine established in Bachan Singh v. State of Punjab (1980). The Court outlined specific criteria—such as the manner of commission, motive, nature and magnitude of the crime, and the status of the victim—to provide a structured framework for determining when the death penalty is appropriate. This decision has significantly influenced the judicial approach to capital punishment in India, ensuring that the death sentence is reserved for cases that shock the collective conscience of society to such an extent that it expects the judiciary to impose the ultimate punishment.

REFERENCES

Machhi Singh And Others vs State Of Punjab on 20 July, 1983
https://www.legalserviceindia.com/

This article is written by Jyoti Kumari student of the Department of Law, United University, and an intern at Legal Vidhya.

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