Archive · 8 Sep 2026
MP High Court Commutes Death Sentence in Child Rape-Murder Case
The Madhya Pradesh High Court reviewed the case of a man convicted of harming and killing a young child.
The child was two years and five months old.
The court agreed that Ram Narayan was guilty.
However, it decided that he should not receive the death penalty.
Instead, he must remain in prison for at least 25 years without remission.
The judges said the crime was extremely serious but did not meet the legal test called “rarest of rare.”
They considered that he had no earlier criminal record and had behaved normally in custody.
The court also canceled the convictions of two other accused people because there was not enough evidence against them for intimidation.
Another accused person had already been acquitted after DNA evidence did not match him.
The Madhya Pradesh High Court upheld Ram Narayan’s conviction for raping and murdering a two-year-five-month-old girl in Shahdol.
The court commuted his death sentence to life imprisonment for at least 25 years without remission.
The bench said the case did not meet the “rarest of rare” standard for capital punishment.
The court considered the victim’s injuries and the prosecution evidence, while also noting contradictions in medical testimony and witness statements.
Convictions of co-accused Rajkumar Dhimar and Pinky Dhimar for criminal intimidation were set aside, while Radheshyam Dhimar’s earlier acquittal stood.
- Who
- The Madhya Pradesh High Court, Ram Narayan alias Bhanu Dhimar, and three co-accused were involved in the proceedings.
- What
- The court upheld Ram Narayan’s conviction but changed his death sentence to life imprisonment for at least 25 years without remission; it also acquitted two co-accused of criminal intimidation.
- When
- The child was injured on the night of March 1, 2023, died on March 7, 2023, and the High Court reviewed the trial court’s January 13, 2026 judgment.
- Where
- The incident occurred in Shahdol district, and the case was heard in the Madhya Pradesh High Court.
- Why
- The court found the offense did not meet the “rarest of rare” threshold for the death penalty and found insufficient evidence against two co-accused on the intimidation charge.
Arguments Supporting Capital Punishment
Arguments Supporting Commutation
Severity of the offense
Arguments Supporting Capital Punishment
The prosecution case involved the rape and murder of an infant who could not resist or report the assault, with severe head and sexual injuries.
Arguments Supporting Commutation
The High Court acknowledged the brutality but held that the overall circumstances did not satisfy the “rarest of rare” standard.
Evidence and conviction
Arguments Supporting Capital Punishment
The prosecution relied on the child’s injuries, the recovery of clothing and a bedsheet, and the matching DNA source swabs; the court upheld Ram Narayan’s conviction.
Arguments Supporting Commutation
The defense pointed to DNA-related issues, contradictions among witnesses, and differences between the treating doctor’s observations and the postmortem findings.
Sentencing factors
Arguments Supporting Capital Punishment
The gravity of the crime was presented as justification for the death penalty imposed by the trial court.
Arguments Supporting Commutation
The High Court cited Ram Narayan’s lack of previous criminal antecedents, economically weak rural background, normal conduct in custody, and other mitigating circumstances in ordering life imprisonment.
- Victim
- A two-year-five-month-old girl
- Incident date
- March 1, 2023
- Date of death
- March 7, 2023
- High Court decision
- Death sentence commuted to life imprisonment for at least 25 years without remission
- Conviction upheld
- Ram Narayan was convicted under provisions of the Indian Penal Code and the Protection of Children from Sexual Offences Act
- Medical findings
- The postmortem recorded a skull fracture and vaginal and anal injuries
- Co-accused outcome
- Rajkumar Dhimar and Pinky Dhimar’s convictions under Section 506 Part-II of the Indian Penal Code were set aside