Revisiting Death Sentence: A Manipur Experience

Written by: Dr N. Brajakanta Singh, Assistant Professor, Department of Law, Dhanamanjuri University, Manipur.

&

Dr O. Satyabati Devi, Assistant Professor, Department of Law, Dhanamanjuri University

Published on: 9th April 2026

Abstract

This paper delves into the sentencing trend of trial courts in capital offences in the country. There are demands that the death sentence be awarded to all horrendous, barbaric, and heinous crimes, especially those that involve kidnapping, rape, and cold-blooded murder of tender age children and helpless women. Since the landmark case of Bachan Singh, the judicial trend is that life imprisonment is the rule, the death penalty is the exception, only to be awarded in the rarest of the rare cases when the alternative option is unquestionably foreclosed. The trial courts in the country are required to satisfy that the state prosecution shall, by evidence, prove the convict cannot be reformed or rehabilitated and thus constitutes a continuing threat to society. In this piece, the authors examine the judgment of a trial court in the state of Manipur, which awarded the death sentence in a murder case. We argue that the case does not fit to be categorised as a rare case.

Key Words: capital offences, death sentence, life imprisonment, rarest of the rare.

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