Bachan Singh v. State of Punjab

The case of Bachan Singh v. State of Punjab (1980) is a landmark judgment in Indian criminal law that addressed the constitutional validity of the death penalty. This case comment examines how the Supreme Court, in a majority decision, upheld capital punishment while simultaneously introducing the “rarest of rare” doctrine to regulate its application. The Court emphasized that the death penalty should be imposed only in exceptional cases where life imprisonment is clearly inadequate, thereby ensuring a more cautious and principled approach to sentencing. The paper analyses the key constitutional issues raised under Articles 14, 19, and 21, along with the arguments presented by both sides. It also highlights the Court’s effort to balance the severity of the crime with the circumstances of the offender, promoting individualized justice. Additionally, the dissenting opinion of Justice P.N. Bhagwati is discussed, which strongly opposed the death penalty on grounds of arbitrariness and the risk of judicial error. Overall, the case comment reflects how Bachan Singh continues to shape India’s death penalty jurisprudence by establishing a framework that is both structured and flexible, aiming to prevent arbitrary imposition of the ultimate punishment.