Supreme Court Order Shows No Verdict Carrying Death Sentence Can Be Final

Says There’s a Provision to Correct Sentencing Errors in Cases of Capital Punishment

August 25, 2025

The Supreme Court has ordered a fresh hearing on the punishment imposed on a man convicted for the rape and murder of a four-year-old girl, setting aside its 2017 judgment that upheld the death penalty. It sets a much-needed precedent where the top court will be willing to review irreversible penalties in light of evolving legal safeguards and human rights obligations.

A Bench of Justices Vikram Nath, Sanjay Karol and Sandeep Mehta delivered the order in response to a petition filed under Article 32 of the Constitution, which grants the right to individuals to directly approach the Supreme Court for the enforcement of their fundamental rights.

The Court ruled that Vasanta Sampta Dupare’s sentencing must be revisited because the mandatory procedures laid out in the 2022 Manoj v State of MP verdict were not followed when his death penalty was confirmed, Bar and Bench reported. That judgment requires detailed examination of mitigating circumstances before a death sentence can be imposed.

The Court said that Article 32 can be used to reopen death sentence cases if important procedures were not followed, especially those linked to the convict’s right to life. It asked the Registry to send the case to the Chief Justice so that a new bench can look at the punishment again. The judges also made it clear that this option should be used only in serious cases and should not be a common way to challenge old verdicts.

The ruling makes clear that the death penalty is different from all other punishments and must follow the strictest procedures. The Court used what is called the “Manoj precedent,” which comes from a 2022 judgment. In that case, the Court said that before giving someone the death sentence, judges must carefully look at the convict’s background, such as age, mental health, family situation, chances of reform and other personal details. By applying this rule even to older cases like Dupare’s, the Court is giving convicts better protection if these steps were skipped earlier.

It also puts tighter limits on the government’s power to take someone’s life through the justice system.

The principle underlying this order is that the irreversible nature of a death sentence requires that every safeguard be not only available in law but actively followed in practice. No human adjudication can be immune from error. Where the penalty is final, even a single lapse in process carries consequences that cannot be undone. Article 32 becomes the tool through which the Court can correct such lapses before it is too late.

The order also affirms a rehabilitative view of justice. The Manoj guidelines direct courts to consider personal history, not just what they did. By enforcing those guidelines even after the sentence has been passed, the Supreme Court has acknowledged that reform is possible, and that the law must keep the door open for it.

Allowing such reviews strengthens the fairness of criminal law in a democracy. Punishment should not be based only on revenge. A just legal system recognises that people can change and should have the chance to do so. This shows respect for human dignity rather than treating past decisions as unchangeable.

The ruling will likely influence trial courts and High Courts to adopt a more rigorous approach in sentencing hearings, particularly in capital cases. The requirement to evaluate mitigating factors with seriousness and depth is now backed by the prospect that any lapse may invite review even after confirmation. This is likely to reduce arbitrary or poorly reasoned death sentences.

By reopening the sentencing, the Supreme Court has shown that true authority includes the willingness to correct mistakes. The Constitution allows the Court to fix its own errors, and it has used that power here to say clearly that the right to life must never be decided through rushed or incomplete processes.

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