What did the Court say about the 'rarest of rare' test?

Use death penalty only when life imprisonment is clearly ruled out, after considering both the crime and the criminal.

Is the balance-sheet method valid?

No. Aggravating factors relate to the crime and mitigating factors to the criminal. They should not be mechanically weighed against each other.

What does life imprisonment mean here?

It means imprisonment for the remainder of natural life unless remission is granted by the competent government.

Does brutality of the crime alone justify death penalty?

No. Sentencing must be individualized, looking at background, possibility of reform, and personal circumstances.

What happened to the death sentence in this case?

The Supreme Court set aside the death sentence and commuted it to life imprisonment, leaving remission to the legal process.

Law Easy

02 November, 2025

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Sangeet and Anr. v. State of Haryana – Death Penalty, Rarest of Rare, Life Imprisonment | The Law Easy

Sangeet and Anr. v. State of Haryana

Supreme Court of India MANU/SC/0989/2012 India Death Penalty 2012 ~6 min

Author: Gulzar Hashmi
Location: India
Publish Date: 2 Nov 2025
Primary Keywords: rarest of rare, death penalty, life imprisonment
Secondary Keywords: individualized sentencing, remission, Bachan Singh, Machhi Singh
Slug: sangeet-and-anr-v-state-of-haryana

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Quick Summary

This case explains how courts should handle death penalty sentencing. The Supreme Court said: do not look only at how brutal the crime is. Look also at who the accused is—background, chances of reform, and personal story. The “rarest of rare” label applies only when life imprisonment is clearly not enough. The Court also said that “life imprisonment” means the whole natural life unless the government grants remission under law.

Categories: Capital Punishment Sentencing Criminal Law

Issues

Does this case fit the “rarest of rare” test for the death penalty?
Should courts consider both the crime and the criminal while sentencing?
Is the “balance-sheet” method of comparing aggravating and mitigating factors legally sound?
Does life imprisonment mean the whole life, or a fixed term with automatic release?

Rules

Rarest of rare: Give death penalty only when life imprisonment is clearly ruled out. Consider both crime and criminal.
Individualized sentencing: Look at background, mental state, and chances of reform. Brutality alone is not enough.
No mechanical balance-sheet: Aggravation relates to the crime; mitigation to the criminal. Do not add and subtract like math.
Meaning of life term: It lasts for the convict’s natural life, unless remission is granted by the competent government.

Facts (Timeline)

Multiple murders in Haryana: The accused attacked a family at night using firearms and a blade weapon.

Motive claimed: belief that the victims practiced black magic linked to a co-accused’s child’s death.

Victims: Ranbir, his wife Bimla, daughter-in-law Seema, and a three-year-old child. One family member survived and testified.

Trial Court: Conviction under IPC and Arms Act. Death sentence for Sangeet and Narender; others got life imprisonment.

High Court: Confirmed death sentence, calling it “rarest of rare,” and labelled Narender a “professional killer.”

Supreme Court: Re-examined sentencing approach and final punishment.

Arguments

Appellant

Death penalty is not automatic even for brutal crimes; the Court must assess the individual and chance of reform.
High Court relied on labels (like “professional killer”) without firm proof.
Balance-sheet of factors is mechanical and not required by Bachan Singh.

Respondent

Crime was pre-planned, cruel, and targeted a child; it falls within the rarest of rare category.
Public interest and deterrence require the ultimate punishment.
Aggravating circumstances outweigh any mitigation.

Judgment

The Supreme Court set aside the death penalty. It said life imprisonment must be the rule, and death penalty the rare exception. The Court stressed that sentencing cannot be judge-centric or arbitrary. It found no solid basis for calling Narender a “professional killer” and no proof that Seema was burned to hide sexual assault evidence. The sentence was changed to life imprisonment, subject to the legal remission process.

Outcome: Death sentence commuted to life imprisonment.

Ratio (Core Principle)

Courts must apply the rarest of rare test by considering both the crime and the criminal. The “balance-sheet” idea is flawed because it mixes unlike things. Life imprisonment means the whole natural life unless remission is granted case-by-case with proper scrutiny.

Why It Matters

Pushes Indian sentencing towards a principled, person-focused model.
Discourages arbitrary use of death penalty through labels and emotions.
Clarifies that life term is truly life, unless remission is lawfully granted.

Key Takeaways

“Rarest of rare” = death only when life term is clearly inadequate.
Look at the person: background, mindset, chance of reform.
No mechanical weighing of “aggravation vs mitigation.”

Life imprisonment = natural life unless remission.
Sentencing must be consistent, not judge-centric.
Strong proof is needed before attaching damaging labels.

Mnemonic & 3-Step Hook

Mnemonic: “Rare-Life-Person” — Rare use of death, Life means life, Person matters.

Ask: Is life term clearly not enough?
Check: What do we know about the person and reform?
Confirm: No mechanical balance-sheet, apply principles.

IRAC Outline

Issue	Rule	Application	Conclusion
Is death penalty justified under rarest of rare?	Death only if life term is foreclosed; consider crime + criminal.	Labels and brutality alone are not enough; look at proof and personal factors.	Not the rarest of rare here; commute to life imprisonment.
Is balance-sheet approach valid?	No. Do not do mechanical factor weighing.	Aggravation (crime) ≠ Mitigation (criminal); they are different categories.	Approach rejected; apply principle-based reasoning.
What is the meaning of life imprisonment?	Natural life unless remission under law.	No automatic release after 14/20 years.	Life term stands; remission is a separate legal process.

Glossary

Rarest of Rare: A narrow category where death penalty is the only suitable punishment.
Mitigating Factors: Details about the accused that can reduce punishment (e.g., youth, reform chances).
Aggravating Factors: Crime-related facts that make the act worse (e.g., extreme cruelty, planning).
Remission: Government’s legal power to reduce the time to be served.

FAQs

Courts must judge both the act and the actor. Death penalty is only when life term surely fails the goals of justice.

No. The Court discouraged adding and subtracting factors like numbers. Sentencing needs principle-based reasoning.

It means the convict’s natural life, unless lawfully reduced by remission.

Their death sentences were commuted to life imprisonment, with remission governed by law.

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