The Supreme Court upheld the conviction of the accused under Sections 376, 377, 302 IPC and Section 5/6 POCSO Act for the sexual assault and murder of a minor. However, it commuted the death penalty to life imprisonment, ruling that the case did not meet the “rarest of rare” standard due to insufficient consideration of mitigating circumstances and rehabilitation potential. The Court emphasized the necessity of balancing aggravating and mitigating factors before imposing capital punishment, following precedents like Mohd. Farooq Abdul Gafur and Gudda v. State of M.P., while affirming the reliability of DNA evidence and the last-seen theory in securing conviction.
Facts Of The Case:
The case involved the brutal sexual assault and murder of a 10-year-old girl in Dehradun, Uttarakhand. On 28th July 2018, the victim was playing outside her home when the accused, Jai Prakash, lured her and other children to his hut under the pretext of giving them money for sweets. While he sent the other children away, he detained the victim, sexually assaulted her, and then strangled her to death, concealing her body under cement bags. Her father lodged an FIR after discovering her body in the accused’s hut. The post-mortem report confirmed rape and death by manual strangulation. The Trial Court and High Court convicted the accused under Sections 376 (rape), 377 (unnatural offences), 302 (murder) IPC, and Section 5/6 POCSO Act, sentencing him to death, citing the crime as “rarest of rare.” The Supreme Court upheld the conviction based on last-seen evidence, witness testimonies, and DNA proof linking the accused to the crime. However, it commuted the death penalty to life imprisonment, ruling that the lower courts failed to adequately consider mitigating factors, such as the accused’s socio-economic background and potential for reform, before imposing capital punishment. The judgment reinforced the principle that brutality alone cannot justify the death penalty without a thorough examination of rehabilitation possibilities.
Procedural History:
The case originated with the FIR registered at P.S. Sahaspur, Dehradun, following the discovery of the victim’s body in the accused’s hut. The Trial Court (Fast Track Court, Special Judge POCSO/Additional District & Sessions Judge, Dehradun) convicted the accused under Sections 376, 377, 302 IPC and Section 5/6 POCSO Act, sentencing him to death on 26th/28th August 2019. The conviction was based on circumstantial evidence, including the last-seen theory, DNA proof, and witness testimonies. The accused appealed to the High Court of Uttarakhand at Nainital, which confirmed the conviction and death sentence on 7th January 2020, agreeing with the Trial Court’s “rarest of rare” classification. The matter then reached the Supreme Court through Criminal Appeal Nos. 331-332 of 2022. While upholding the conviction, the Supreme Court (Judgment dated 16th July 2025) commuted the death penalty to life imprisonment, criticizing the lower courts for insufficient consideration of mitigating factors and rehabilitation potential. The SC emphasized the necessity of a balanced sentencing approach in capital cases, aligning with precedents like Mohd. Farooq Abdul Gafur and Gudda v. State of M.P..
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Court Observation:
The Supreme Court made several critical observations while upholding the conviction but commuting the death sentence to life imprisonment. It affirmed the reliability of circumstantial evidence, including the last-seen theory and DNA analysis, which conclusively linked the accused to the crime. The Court noted the brutality of the offence—sexual assault and murder of a 10-year-old—but emphasized that heinousness alone cannot justify the death penalty without examining mitigating factors. It criticized the lower courts for failing to conduct a thorough sentencing analysis, particularly in assessing the accused’s socio-economic background, potential for reform, and possibility of rehabilitation.The judgment reiterated the two-step test for imposing the death penalty: (1) whether the case falls under the “rarest of rare” category, and (2) whether life imprisonment is unquestionably inadequate. The Court found that the lower courts focused excessively on the crime’s brutality while ignoring mitigating circumstances, such as the accused’s impoverished upbringing and lack of prior criminal record. Citing precedents like Mohd. Farooq Abdul Gafur and Gudda v. State of M.P., the Court underscored that capital punishment requires strict scrutiny and a balanced consideration of aggravating and mitigating factors.Ultimately, the Supreme Court ruled that the case did not meet the “rarest of rare” standard, as the possibility of reformation could not be definitively ruled out. It thus commuted the death sentence to life imprisonment, reinforcing the principle that the death penalty should be imposed only in the most exceptional cases where alternative punishments are wholly inadequate.
Final Decision & Judgement:
In its final judgment dated July 16, 2025, the Supreme Court of India upheld the conviction of the accused, Jai Prakash, under Sections 376 (rape), 377 (unnatural offences), and 302 (murder) of the IPC, as well as Section 5/6 of the POCSO Act, for the sexual assault and murder of a 10-year-old girl. However, the Court set aside the death penalty imposed by the Trial Court and affirmed by the High Court, commuting it to life imprisonment without remission for the remainder of the accused’s natural life.The three-judge bench (Justices Vikram Nath, Sanjay Karol, and Sandeep Mehta) ruled that while the prosecution had conclusively proven guilt through circumstantial evidence, DNA analysis, and witness testimonies, the lower courts erred in sentencing by failing to adequately consider mitigating factors—such as the accused’s socio-economic background, lack of prior criminality, and potential for reformation. The Court emphasized that the “rarest of rare” doctrine requires a balanced assessment of both aggravating and mitigating circumstances, and mere brutality of the crime cannot automatically justify capital punishment.Citing precedents like Mohd. Farooq Abdul Gafur and Gudda v. State of M.P., the Supreme Court clarified that the death penalty should be reserved for cases where no alternative punishment suffices and rehabilitation is impossible. Since the lower courts had not conducted this rigorous analysis, the Supreme Court modified the sentence to life imprisonment, ensuring the accused remains incarcerated for life but sparing him the death penalty. The judgment reinforces India’s evolving jurisprudence on capital punishment, prioritizing proportionality and judicial restraint in sentencing.
Case Details:
Case Title: Jai Prakash vs. State of Uttarakhand Citation: 2025 INSC 861 Criminal Appeal No.: Criminal Appeal Nos. 331-332 of 2022 Date of Judgment: 16th July 2025 Judges/Justice Name: Justice Vikram Nath & Justice Sanjay Karol & Justice Sandeep Mehta
Download The Judgement Here