Archive · 22 Sep 2026
Supreme Court Safeguards Questioned in Uttar Pradesh Death Sentences
India still allows courts to impose the death penalty.
The writer says judges must follow special legal safeguards before choosing it.
A trial judge in Muzaffarnagar sentenced 23 people to death in nine decisions.
The judgments are criticized for focusing mainly on how terrible the crimes were.
The Supreme Court has said judges must also study each accused person’s life and circumstances.
This includes looking at their background, mental health, and chances of changing.
A 2022 decision called Manoj described reports that should help judges do this.
The article says those safeguards were not meaningfully used in the 23 cases.
It also says that only eight of 216 reviewed cases followed the safeguards, so the problem may be widespread.
An Uttar Pradesh trial judge sentenced 23 people to death across nine judgments over approximately five months.
The judgments allegedly focused heavily on the brutality and circumstances of the crimes rather than individualized assessments of the accused.
The Supreme Court’s Bachan Singh ruling requires courts to consider both the crime and the accused’s circumstances before imposing death.
The Manoj ruling requires reports and assessments addressing an accused’s background, mental condition, and prospects of reform.
NALSAR’s Square Circle Clinic found that only eight of 216 death-sentence cases from 2023 to 2025 complied with the Manoj requirements.
- Who
- An Additional District and Sessions Judge in Muzaffarnagar sentenced 23 people to death; the analysis was written by a law professor and executive director of The Square Circle Clinic at NALSAR University of Law.
- What
- The article argues that the 23 death sentences may have been imposed without following Supreme Court requirements for individualized sentencing and mitigation review.
- When
- The sentences were imposed over approximately five months; the relevant Supreme Court decisions were issued in 1980, May 2022, and August 2025.
- Where
- Muzaffarnagar, Uttar Pradesh, India; the article also cites data from death-sentence cases across India.
- Why
- The writer says courts must follow legally required safeguards because death sentences affect fundamental rights and cannot rest only on the brutality of a crime.
- Death sentences examined
- 23 people were sentenced to death in nine judgments by the Muzaffarnagar Additional District and Sessions Judge.
- Relevant 1980 ruling
- Bachan Singh v. State of Punjab requires consideration of both the crime and the accused’s circumstances.
- Manoj decision
- The Supreme Court’s May 2022 decision called for material such as probation, prison, psychological, psychiatric, and defence mitigation reports.
- Later ruling
- Vasanta Sampat Dupare v. Union of India, decided in August 2025, said ignoring the Manoj safeguards violates fundamental rights.
- Cases reviewed
- The Square Circle Clinic analyzed 216 trial-court death sentences imposed across India from 2023 to 2025.
- Compliance rate
- According to the article’s data, eight of 216 cases—less than 4%—complied with the Supreme Court’s requirements.