Supreme Court of India Case number CRL. APPEAL NOS. 2220-2221 OF 2022 Petitioner Deen Dayal Tiwari Respondent State of Uttar Pradesh Date of Judgement 16/01/2025 Bench Justice Vikram Nath, Justice Sanjay Karol, Justice Sandeep Mehta
Facts of the Case
- Background:
The appellant, Deen Dayal Tiwari, lived in Faizabad (now Ayodhya), Uttar Pradesh, with his wife Siyallali and their four minor daughters—Mani, Riya, Guddan, and Mahima. - Incident:
On the night of November 11-12, 2011, at around 2:30 a.m., the appellant’s brother (PW-1) and his wife (PW-2) heard distress cries from the appellant’s house. They rushed to the scene but found the door locked from the inside. Despite their pleas and threats to break it open, the appellant did not open the door.PW-1 later saw the appellant briefly emerge, holding a blood-stained axe, and threatening to kill anyone who intervened. He then went back inside and locked the door. PW-1 proceeded to the police station around 6:10 a.m. to lodge an FIR under Section 302 IPC. - Investigation:
- Police arrived in the morning, broke open the door, and found the appellant inside the room with a blood-stained axe.
- The bodies of his wife and four daughters were discovered in pools of blood.
- Upon interrogation, the appellant allegedly confessed to the murders.
- A forensic examination confirmed multiple incised wounds on the victims, consistent with the use of an axe and knives.
- Trial Court Verdict:
- The Sessions Court found the appellant guilty under Section 302 IPC.
- He was sentenced to death, as the court deemed it a “rarest of rare” case.
- High Court Appeal:
- The High Court upheld the conviction and death sentence.
Legal Issues Involved
- Whether the appellant’s conviction under Section 302 IPC was based on proper legal grounds.
- Whether the circumstantial evidence was sufficient to prove guilt beyond a reasonable doubt.
- Whether the case met the “rarest of rare” standard for awarding the death penalty.
- Whether the appellant’s defense (alibi and claims of false implication) held merit.
- Whether the High Court erred in confirming the death penalty.
Supreme Court’s Decision
- Conviction Upheld:
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- The Supreme Court upheld the conviction of the appellant under Section 302 IPC.
- The Court found that the circumstantial evidence formed an unbroken chain pointing to the guilt of the appellant.
The appellant’s failure to provide a reasonable explanation for the murders under Section 106 of the Indian Evidence Act reinforced the inference of guilt.
- Death Sentence Commuted to Life Imprisonment:
- While the Court condemned the brutality of the crime, it observed mitigating factors:
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- The appellant had no prior criminal history.
- His conduct in jail was satisfactory.
- There was potential for reformation.
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- Referring to precedents like Bachan Singh v. State of Punjab (1980) and Swamy Shraddananda v. State of Karnataka (2008), the Court ruled that life imprisonment without remission was a more appropriate punishment.
- The sentence was modified to life imprisonment till the appellant’s natural lifespan.
Key Ratio Decidendi
- Circumstantial Evidence & Burden of Proof:
The Court reiterated that conviction based on circumstantial evidence must establish a complete chain ruling out any hypothesis of innocence. The appellant’s presence at the crime scene with a weapon and lack of a valid alibi satisfied this requirement. - Application of ‘Rarest of Rare’ Doctrine:
The Court emphasized that capital punishment should be awarded only when alternative sentencing is “unquestionably foreclosed.” The presence of mitigating factors warranted commutation.
Conclusion
Final Verdict: The Supreme Court upheld the conviction under Section 302 IPC but commuted the death sentence to life imprisonment till the appellant’s last breath.
Significance: The case reaffirmed the judiciary’s approach to balancing crime severity with reformation possibilities in sentencing decisions.
Reference
- R. Bommai v. Union of India – Wikipedia
- Case details on Indian Supreme Court website
- Legal Service India article on S. R. Bommai v. Union of India
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