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Capital Punishment in India: Critical Analysis

In India, the motive behind giving the punishment is based on two aspects, the first one is that the wrongdoer should have to suffer and the other is to discourage others from doing wrong by imposing punishment on wrongdoers. Death Penalty or Capital Punishment has always been a point of contradiction not only in the Indian Judiciary but also in most developed countries.

The state's authority is both questioned and established after the execution of Capital Punishment. India has made its stance clear on this matter in December 2007 and despite its stance, the Judiciary spares it for extraordinary infringement of the law.

There are many human rights movements in India according to which capital punishment is immoral because it affects one person's right. Capital punishment has become more controversial as time passes. The general population, who restrict this training, announce it to be heartless and out of line. They accept that no life ought to be taken, paying little respect to the wrongdoing that has been committed.

The main aim of this article is to give the reader a clear understanding of the condition and view of the Indian Courts in regard to the awarding of Capital Punishment. It concludes with legality of capital punishment.

Introduction
In India, the motive behind giving the punishment relies on two aspects, the primary one is that the offender should need to suffer and the other is to discourage others from doing wrong by imposing a penalty on wrongdoers. Amongst the various forms of punishment for a crime in India, this article focuses on the death penalty that is additionally called the death penalty that is awarded by the court in the rarest of rare cases.

Capital punishment or the death penalty has always been a point of contradiction not only in the Indian Judiciary however also in most developed countries. The state's authority is both questioned and established after the execution of the death penalty.

There are many human rights movements in India according to which the death penalty is immoral because it affects one person's right. The Indian Criminal jurisprudence relies on the combination of two theories: one is the reformative theory, according to that crime looks like a disease. This theory believes that "You cannot cure by killing".

The main aim of this theory is to bring a change in the personality and character of the wrongdoer, to make him a helpful member of society. The other theory that is followed is Preventive Theory, which says 'Prevention is better than cure. It's better to take prevention before the commitment of a crime. This theory aims at preventing crime by disabling crime by imposing capital punishment on the criminal, or by confining him in jail.

The Indian Constitution likewise offered forces to the President and representative to suspend or exculpate the death penalty. In India, capital punishment is granted for the most genuine and frightful offences. Capital punishment is given for murder, theft with murder, taking up arms against the administration and so forth. This penalty is given when the court arrives at an end that life detainment is lacking, in view of the circumstances of the case.[1]

Objectives of the Study
The objective of the study is to try and find the validity of capital punishment and view of public on capital punishment in India.

Research Problem
India's view on the issue of capital punishment is still very topsy-turvy. The debate isn't only regarding the legality of the punishment however also include social and moral aspects. If the question of law is kept aside, two views the issue given on the difficulty. The primary view is the security of society and the public sentiments.

The counter view is that it promotes the principle of "eye for an eye" that can't be accepted in a civilized society. On one hand, by retaining the death sentence, we might condemn someone to death, who turns out to be innocent. On the other hand, by giving a second chance to someone, we would be giving them a bullet to shoot us, just because they missed the primary time.

It is still not clear whether capital punishment is valid and necessary. This paper tries to find the answers for the same.

Research Questions
  • What is the test that's required to give capital punishment to a person in India?
  • Whether the death penalty is an appropriate mode for society in the present era?
  • What are the arguments that are against or in the favour of capital punishment?

Research Methodology
The research methodology used in the research paper is doctrinal and relies on secondary sources. The secondary sources of information include online websites, research papers, books based on the Indian penal code, Reports published by renowned authorities, newspapers, legal databases that help us to give an interpretation on various cases, etc.

Literature Review
There is a variety of material that's available on the concept of the death penalty. The literature review is analysed in such a way, so, as to ascertain the work that has been done by various scholars on this idea so far.

According to Article 6 of ICCPR, 1979 that provides the right to life is a wider concept and the death penalty should only be given in serious crimes however only minority states abolished it till 1954. ECOSOC in 1984 affirmed that capital punishment shouldn't have extreme consequences.

Bentham's theory of utility, greatest good for greatest number offers that culprits through the death penalty can be removed for the greater good of the society. Similarly, Raffaele Garofalo, an Italian jurist actually supported the death penalty.

Mahatma Gandhi is one who was against the death penalty as he believed that Ahimsa is the only way to handle matters. He beseeched Hate Sin however not the sinner. Dr Ambhedkar believed in the principles of non-violence to be considered as a moral mandate.

The theory of the death penalty based on the rarest of rare cases relies on deterrent and retributive theory. The deterrent theory aims to punish an offender to create a sense of fear in his mind and abstain to commit the crime again, whereas retributive theory relies on the principle of the tooth for tooth and an eye for an eye.

In India, there are various laws that have the provision of capital punishment like under Indian penal code, 1860 ( Sec. 120- B, 121,132, 302, 303, 305, 364 A, 376 AB, etc.), Commission of Sati Act,1987, 1985, Protection of children from sexual harassment Act, 2012 and criminal law amendment Act, 2013, etc.

The Law Commission 187th Report considered ascertaining the mode of execution during capital punishment however it didn't draw attention towards the constitutionality of capital punishment. In its 262nd report on capital punishment, the Law Commission stated that the practice of capital punishment should be abolished and should only be restricted to cases of terrorism and waging war against the State.

The capital punishment of India Report focuses on the socio-economic conditions of the prisoners who are sentenced to the death penalty in India. More than 74.1% are economically vulnerable prisoners. It provides various views on the debate of the abolition of the death penalty.

Dr S. Murlidhar in his article examines the test that has been applied for capital punishment and states that there's a need to understand the restrictions of the judicial system and the importance of retributive theory in bringing the impact of peace and non-violence.

The Ministry of Home Affairs states that capital punishment is no deterrent to murder and for the same, it's approached the Supreme Court to modify guidelines related to capital punishment and focusing it more to be victim-centric.

Analysis
In India, the death penalty is principally given for brutal crimes. The President has the facility to grant mercy in capital punishment cases. When an individual has been given the death penalty by the Sessions Court, it should be affirmed by the high court. If the convict appeals in the Supreme Court and fails then at that time the convict can ask a mercy petition to the President of India. The Ministry of Home Affairs will set out the Appeals made to the Supreme Court and the solicitations made for the extraordinary leave to appeal to the Court by the convict.[2]

Capital punishment should be maintained to safeguard society from criminals. The main aim behind the execution of capital punishment is to satisfy society's feeling of hatred towards crimes. The security of the society lies in removing the criminals from the society and the mercy petitions should be rejected by the president and by the governor.

There's no alternative punishment for the death penalty as such, imprisonment is considered as an alternate at times, and however, it's a lesser impact. The crime rate keeps on increasing. If one offender is punished with capital punishment it sets an example for other offenders. By giving lesser punishment the criminal will continue to do the same offence. Compared to imprisonment, capital punishment is quick and painless. If capital punishment is abolished it might encourage the criminal.

Like a coin with two sides, capital punishment also has a negative impact on society. This penalty is an admission of the state's failure to achieve deterrence by threat of the death penalty. A criminal is also a human being and they can be reformed. Capital punishment is barbaric and cruel.

The rich rule the law and escapes from punishment, whereas the poor become its prey. Morally it's unjustifiable because it's a murder by the state. Capital punishment itself is an offence against humanity. Nobody has a right to kill another person because God has given it this life. If the state executes capital punishment, the state is considered to commit an offence of murder.[3]

Crimes associated with capital punishment
The crimes which are deserving of death are:
Aggravated murder
According to Section 302 of the Indian penal code, 1860, an individual who commits murder shall be given the death penalty. In Bachan Singh's case, the Court held that the death penalty is constitutional only when it's applied as an exception in "the rarest of the rare" cases.

Other offences resulting in death
In the Indian penal code, the death penalty is given to an individual who submits a murder during a furnished theft. Submitting or submitting Sati to someone else is additionally deserving of the death penalty.

Terrorism- related offences not resulting in Death
The utilization of any exceptional classification of explosives thus as to complete a blast that could jeopardize one's life or cause genuine hurt to one's property is deserving of capital punishment.

Rape not leading to Death
An individual who inflicts injury in rape, because of that he passes on or is left in a "persistent vegetative state" might be granted the death penalty under the criminal law Act, 2013.
Gang rapes are punishable with the death penalty. These were formed when the gang rape of medicinal understudy Jyoti Singh Pandey in 2012 in New Delhi.

As indicated by the 2018 criminal law Ordinance, an individual who rapes a young lady beneath the age of twelve can be given life detainment or sent to jail for a long time alongside a fine. The alteration done in 2018 additionally indicates the capital punishment or life detainment for the gang rape of a young lady who is younger than twelve. These progressions were done in the criminal law after the gang rape and murder of an eight-year-old young girl named Asifa Bano, who set off a ton of political agitation in Jammu and over the entire nation.

Kidnapping not resulting in Death
As indicated by Section 364A of the Indian penal code, 1860, grabbing not bringing about death is an offence deserving of the death penalty. On the off chance that anyone kidnapped somebody and takes steps to kill him during which the abductor act brings about the death of the person in question, he will be at risk under this section.

Drug trafficking not resulting in Death
On the off chance that an individual endeavour to commit any of the scopes of drug trafficking offences or financing such kind of drug-related acts, the person in question can be condemned to death. Punished by the death penalty.

Treason
An individual who attempts to take up arms or is taking up arms against the administration and helping Navy, Army or Air Force officials, troopers or individuals to submit a revolt will be rebuffed by the death penalty.

Military offences not resulting in Death
If a member of the army, Navy or Air Force commits an abetment of assault, mutiny, and other related offences, he shall be punished by the death penalty.

Other offences not resulting in death
  1. If a person is a party to criminal conspiracy in order to commit a capital offence, he's punishable by the death penalty.
  2. A person who attempts to kill a life convict is punishable by a death sentence if the victim is harmed in the attempt.
  3. If an individual provides any false evidence against an innocent person, despite being of the knowledge that based on that evidence that person can be given a punishment of death penalty, and if it results in the execution of an innocent person, then the person who provides such evidence will be given the death penalty.

Category of offenders excluded from capital punishment
  • Minor
    As per Indian Law, an individual who is younger than eighteen years at the time of commitment to the crime can't be given capital punishment.
     
  • Pregnant woman
    As per the alteration made in the year 2009, Clemency must be conceded to a pregnant lady who is condemned to the death penalty.
     
  • Intellectually Disabled
    As indicated by the Indian penal code, an individual whereas committing out grievous wrongdoing, was rationally sick or can't comprehend that the nature of the demonstration performed by him is risky, can't be rebuffed by capital punishment.[4]

Law Commission Report
A discussion on capital punishment cannot be complete while not taking into consideration the 36thReport of the Law Commission of India, which was submitted by the Law Commission in 1967.

The Report stated that the issue of abolition or retention of capital punishment should be determined after balancing the arguments given in favour and in against of death penalty. A single factor cannot decide the question of abolition or retention of the death penalty in the country. The Report also vocally stated that the question of protecting society must be given prime consideration whereas deciding the issue.

The Commission did consider the strong arguments given for the abolition of capital punishment. They also considered the concept of irrevocability attached to the punishment of the death penalty. Nor did they ignore the fact that capital punishment was very severe, and a modern approach was required to handle criminals. however considering the state of the nation, the Commission stated that keeping in mind the manner of the upbringing of the citizen, the disparity level in educational and moral levels of the individuals, the vastness of the area, the variety of the nation and the utmost need to preserve law and order, India cannot risk abolishing the death penalty, however.

In the judicial pronouncement of Ediga Anamma v State of Andhra Pradesh, Justice Krishna Iyer commuted the death sentence of the accused to imprisonment considering factors like gender, age and socio-economic background of the accused. In this case, the Court set out that except for looking into the circumstances of the crime, the Court should also look into the condition of the accused.

This case was followed by some necessary developments. Section 354 (3) was added to the Code of Criminal Procedure, 1973 that expressed that in cases where capital punishment was being awarded, the Court has to give special reasons for it. This made imprisonment a rule, and the death penalty an exception that was the other manner around earlier.

In 1979, India also became a signatory to the International Covenant on Civil and Political Rights (ICCPR). In the case of Rajendra Prasad v State of U.P the Apex Court, however, stated that the question of whether capital punishment should be abolished or retained was a question for the legislature and not for the Courts to determine.

The case of Bachchan Singh v State of Punjab again brought up the question of the validity of capital punishment and in this case, the doctrine of "rarest of the rare" was formulated. The five-judge Bench declared that the taking of human life shouldn't be encouraged even in the kind of punishment except in "rarest of the rare" cases where no alternative method can be used and is foreclosed.

When the validity of capital punishment was questioned, the bench (majority decision) opined that capital punishment did not violate either Article 19 or Article 21 of the Constitution. They also pointed out the fact that the makers of the Constitution were totally aware that capital punishment may be awarded in some cases, and it was proved by the existence of the provision of appeal and provision of pardoning powers of the President and the Governor. It was also laid down that mitigating, and aggravating factors should be considered while deciding the matter.

In the judicial pronouncement of Mithu v. State of Punjab, mandatory death sentence, under Section 303 of IPC was declared unconstitutional and deleted from the IPC. This section was based on the logic that any criminal who has been convicted for life and has committed a murder while in custody is beyond reformation and don't deserve to live.

The case of Machchi Singh v State of Punjab elaborated the doctrine of "rarest of rare." The Court gave guidelines regarding the things to be considered when deciding on the issue that whether the case falls under the category of "rarest of rare" or not.

The following are:
  1. Manner of Commission of the Crime:
    The Court declared that if the crime were committed in extremely brutal and diabolic manners so that it arouses the intense outrage of the society, it'd fall under the rarest of the rare case. Some instances were given like when the house of the victim is set to flame with the objective to burn him alive, or the victim is subjected to inhuman cruelty and torture, or when the body of the victim is chopped and mutilated, it'll be thought of as a rarest of rare case.
     
  2. Motive for Commission of the Crime:
    when the crime is committed in furtherance to betray the nation, or assassins are employed to kill the victim, or any deliberate design is made to kill the victim in a cold-blooded manner, it'll also fall under the said class of rarest of the rare.
     
  3. Magnitude of the Crime:
    when the crime is large in proportion, for example, killing all the members of the family or a locality is done.
     
  4. Socially obscene Nature of Crime:
    when the crime is such it's socially abhorred, like killing someone belonging to the backward categories of the community or burning of a bride in case dowry wishes aren't met or murdering a woman to remarry again.
     
  5. Victim of the Crime:
    If the victim of the crime is a small child, who couldn't have provided any reason to the accused to commit the crime, or the crime is committed against a helpless woman, or an old person, and if the victim was mentally challenged, or the victim was a public figure who was loved by the society, the crime will fall under rarest of the rare case.[5]

Principle-based on capital punishment in India - the doctrine of 'rarest of the Rare' Cases:
Capital punishment in India relies on the doctrine of the rarest cases. The doctrine implies that to sentence a person for death the crime check should be fully happy and it shouldn't favour the accused in any circumstances.

This philosophy depends upon the perception that society takes and the court should consider a variety of factors like society's hatred, the personality of the criminal, motive and manner of the commission of the crime, extreme indignations and antipathy to sure crimes like rape of minor girls etc.

The courts award the death sentence because it's the situation that demands it due to constitutional compulsion that reflects the will of the society and not the judge- centric approach of the society. However, capital punishment can only be awarded in special circumstances and there should be a balance between mitigating as well as aggravating factors.

The applicability of this doctrine is ambiguous as Justice Bhagwati himself believed that the life of an offender decided by the minds of the bench is violative of the fundamental rights as guaranteed in Article 14 and Article 21 of the Indian Constitution.

The philosophy of the rarest of the rare case was established in the case of Bacchan Singh v/s State of Punjab, the court provided the principles and guidelines that should be considered in granting capital punishment to someone is as follows:
A court could impose capital punishment, if:
  • If the murder has been committed after previous planning and involves extreme brutality.
  • If the murder involves exceptional depravity or murder has been committed of someone on public duty.
  • Capital punishment shouldn't be given in every case; instead, it should be given on the idea of the culpability of various cases. Before granting such punishment, the circumstances of the offender and the crime should be taken care of.
  • The punishment will only be given when life imprisonment falls short of the crime done by the offender.
  • Both aggravating and mitigating factors should also be considered and the balance between them must be maintained.

The court while giving a death sentence should be rigorous and honest irrespective of the emotions and the sentiments. One should consider the social nature of the crime as a murderer may belong to a backward category and cases like the burning of a bride; dowry death comes under the scope of it.

The personality of a criminal plays a major role as the accused is also an innocent child, a helpless woman. Therefore, the doctrine should only be followed when the crime committed is rare in nature and a man of normal prudence with reasonableness wouldn't commit it. On the other hand, the accused has the right to be heard, appeal and pray before the President.

Considering the scope of this doctrine, the Supreme Court held that the constitutional validity of this doctrine and held that the purpose of this doctrine isn't to be a rational motive however a gesture to disapprove the crime on the part of society and if this doctrine or death penalty is abolished then it will be riskier for the society.

Thus, the doctrine or the philosophy of the rarest of the rare case in India is strictly followed with a high degree of consideration in giving capital punishment as the offenders do have their fundamental rights however that doesn't mean that they should be simply left. The circumstances and the facts are highly considered and then the punishment is awarded until and unless the crime is extremely grievous and it harms the ethics of the society and acts as a model so as that people fear not to indulge and commit such crimes again.[6]

Judicial review: A Look at some of the landmark cases
The awarding death penalty has been one of the most controversial topics of all time. There have been various cases, but the following 3 cases are landmark cases regarding the death penalty.

Jagmohan Singh v. State of Uttar Pradesh (1973)
The Jagmohan Singh case was important because it challenged the constitutionality of the death penalty. The Supreme Court stated that while analysing Article 21 and Article 72 of the Constitution, it cannot be said that capital sentence was regarded per se unreasonable or not in the public interest. Thus, SC upheld that the death penalty can be attributed to various crimes. However, an amendment was made in CrPC, which changed the death penalty from being the norm to an exception.

Bachan Singh v. State of Punjab (1980)
Undoubtedly, the most important case in death penalty jurisprudence in India is Bachan Singh v Union on India. In this case, the Supreme Court examined the constitutional validity of the death penalty. The moot problem addressed in this case was whether the sentencing procedure prescribed under Section 354(3) of CrPC is unconstitutional to the extents that it vests the Court with unguided discretion in imposing the death penalty.

The majority of judges held that the discretion vested with the judges in awarding the death penalty is not unguided because it is exercised in accordance with the well-recognised principles crystallized by precedents. Therefore, the discretion vested with the judges is not violative of Article 14 and 21 of the Constitution. However, Justice Bagawati in his minority opinion stated that awarding the death penalty as an alternative to life imprisonment was unconstitutional because it confers unfettered discretion on the judges to choose between the death penalty and life imprisonment.

In Bachan Singh, the court had derived the rarest of rare doctrine to ensure that the judges are not conferred with unguided discretion in awarding capital punishment. According to the doctrine, life imprisonment is the rule and death sentence an exception and the death penalty should be awarded only when all the alternatives are unquestionably foreclosed. It also mandated the judges to consider the aggravating and mitigating factors of the case which includes the circumstances of the crime and criminal in determining punishment.

The Court mandated a pre-sentencing hearing to examine the aggravating and mitigating circumstances. However, the question we need to address now, i.e. after 40 years of Bachan Singh, is whether the court was successful in creating a coherent and consistent basis for death penalty jurisprudence in India.

Machhi Singh v. State of Punjab (1983)
The Machchi Singh case is important because it was in this case that the Supreme Court laid down the criteria which would make cases "the rarest of rare" and thus could invite the death penalty.[7]

Arguments against Capital Punishment:
Human life is considered to be a valuable thing and people presume that even the offenders in their worst case shouldn't be deprived of their right to life. Their right to life can't be taken away simply because of their bad conduct. It's the obligation of the State to safeguard the society and punish the offenders however it should be done in the least harmful way and other various alternatives are chosen to punish the wrongdoer.

Capital punishment leads to the execution of innocent people because of the deficiency in the system of justice. People included in the sphere of justice like prosecutors, witnesses and the jurat may be in error.

It is simply an act of violence that leads to the risk of taking the lives of innocents. People believe that capital punishment based on retribution to provide justice is morally wrong and is simply an emerged form of revenge. Killing can't be termed as wrong by killing. People that believe the theory of retribution argue that the death penalty is against it as sentencing imprisonment to a wrongdoer can cause endless pain to the wrongdoer. Such punishment has failed to provide the deterrence effect as social scientists consensus proves that it affects only a small percentage of murderers.

Capital punishment only leads to the brutalization of society as well as the state's relation with its citizens. The approach by which the political and social issues in society will be curbed by killing is morally wrong and unacceptable. The current society doesn't endure torture and capital punishment isn't the answer to deal with dreadful crimes.

Arguments for Capital Punishment:
The primary argument that supports capital punishment is that every guilty person should be punished and the punishment shall be proportional to the crime that he/she has committed. This argument supports the idea of justice. J. Anand and J. N.P. Singh in one of their judgments stated that:
Imposition of appropriate punishment is the way by which one can respond to society's cry for justice against the criminals. Justice asks for imposing punishment and befitting crime, so, that it can contemplate hatred of the crime.

Society has always utilised punishment as a mode to discourage criminals since society aims to reduce heinous crimes, therefore, the strongest punishment shall be awarded and capital punishment is apt for it. Offenders should be killed to prevent them from committing a crime again. It's considered sensible to kill a person who is dangerous to the community and execution is treated as a remedy to safeguard the interest of society.

There is no proof that capital punishment has taken the lives of innocent people, even if any case appears, it's rare to happen. Discretion has always played a significant role, every case has different circumstances and they are minutely observed. Hence, it shouldn't be considered discriminatory in nature. The fear definitely impacts human psychology, therefore, the death penalty ensures that the violation of any law shall not be taken in a lighter way; mandatory actions shall be enforced to uphold the law.[8]

Future of capital punishment in India
In Chhannulal Verma v. the State of Chattisgarh, Justice Kurian Joseph in his dissenting opinion expressed his various concerns over the inconsistent application of the principles laid down in Bachan Singh. In this case, he opined that the constitutional regulation of the death penalty attempted in Bachan Singh has failed to prevent death sentences from being "arbitrarily and freakishly imposed" and that death penalty has failed to achieve any constitutionally valid penological goals.[9]

Conclusion
India is a democratic country and the preamble mentions, we the people of India where the advantage of people at large prevails. The Constitution of India guarantees people to live in a dignified manner, for this, the State can punish anyone against the crime that's done against it. Considering the punishments, the death penalty is the highest punishment that one can get irrespective of one's (accused) right and dignity. India being a member of the Universal Declaration of Human Rights didn't abolish the death penalty however restricted the scope of such practice by establishing the philosophy of the rarest of rare cases.

Capital punishment is considered the most inhuman and cruel punishment in the world. Several countries have abolished however India being an active member of the United Nations and numerous other commissions of Human Rights has not abolished it yet. According to our judiciary, it's only implemented in exceptional circumstances that are rarest of rare. India is a diverse country and based on rich culture. It's not the fact that crimes are originated in modern times and therefore, such punishment should be given.

Capital punishment in rarest of rarest cases doesn't affect the principles of Human Rights as stated by ICCPR (The International Covenant on Civil and Political Rights) for those countries that have still not abolished it however with some restrictions imposed on it.

The Supreme Court has, in various cases, declared that capital punishment shouldn't be declared unconstitutional, as a result of the framers of the Constitution hasn't seen it appropriate to do this, and that the legislature also hasn't taken any steps to abolish the capital punishment.

However, there are various arguments that contend for abolishing capital punishment. The emotional stigma of revenge would lead us nowhere else than in a cycle of violence and sadness. Thus, in my view, executing criminals by awarding them capital punishment should be abolished and that there's no place in the modern world for such killings by the State, and that India should abolish capital punishment as soon as possible.

From the analysis of various judgments pronounced by the Courts, I understood that there's no uniformity in precedents. The subjective and arbitrary awarding of capital punishment has made the capital punishment jurisprudence into 'judge centric jurisprudence'.

The personal morality (predilection) of judges is more vital than the principles laid by precedents. This has created uncertainty in the outcome of capital punishment litigation and the same has been acknowledged in various judgments. Therefore, it's high time for the Judiciary to rethink the constitutionality of capital punishment in India.

Bibliography:
  • Overview and Analysis of Capital Punishment in India (ipleaders.in)
  • Capital punishment in India - An Overview - iPleaders
  • Death Sentence in India - IPC - Death penalty (legalserviceindia.com)
  • Death Penalty in India (legalserviceindia.com)
  • Death Penalty in India (amicusx.com)
  • Abolition of Death Penalty in India: A Case Study - The Law Blog
  • Debate On death penalty - iPleaders
End-Notes:
  1. Rai, Diva. "Overview and Analysis of Capital Punishment in India." IPleaders, 24 July 2019, blog.ipleaders.in/capital-punishment-2/.
  2. Rai, Diva. "Overview and Analysis of Capital Punishment in India." IPleaders, 24 July 2019, blog.ipleaders.in/capital-punishment-2/.
  3. Death Penalty in India (May. 7, 2020), https://www.amicusx.com/post/death-penalty-in-india.
  4. Rai, Diva. "Overview and Analysis of Capital Punishment in India." IPleaders, 24 July 2019, blog.ipleaders.in/capital-punishment-2/.
  5. R Furtado, Capital punishment in India - An Overview - iPleaders ( Jul. 1, 2016), https://blog.ipleaders.in/capital-punishment-india-overview/.
  6. G Sharma, Death Penalty in India (. , ), http://www.legalserviceindia.com/legal/article-3212-death-penalty-in-india.html
  7. Debate On death penalty - iPleaders ( Mar. 18, 2018), https://blog.ipleaders.in/debate-death-penalty/.
  8. G Sharma, Death Penalty in India (. , ), http://www.legalserviceindia.com/legal/article-3212-death-penalty-in-india.html.
  9. Debate On death penalty - iPleaders ( Mar. 18, 2018), https://blog.ipleaders.in/debate-death-penalty/.

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