Supreme Court Sets Aside Death Sentence In Double-Murder Case, Orders Fresh Trial Citing Multiple Fair‑trial Lapses

A bench of Justices Vikram Nath, Sanjay Karol and Sandeep Mehta heard appeals challenging the confirmation of a death sentence awarded by a Sessions Court and upheld by the High Court of Judicature at Allahabad in a double‑murder trial arising out of Mainpuri (Criminal Appeal Nos. 259‑260 of 2019). The appeals assailed both conviction and sentence imposed on the appellant for offences under Sections 302 and 201 IPC in respect of the deaths of his wife and daughter.

The Court allowed the appeals, set aside the conviction and the sentence of death and remanded the matter for a fresh trial beginning from the stage of framing of charge. The Court held that multiple procedural and systemic lapses cumulatively vitiated the trial and prejudiced the accused’s statutory and constitutional rights to a fair trial under Article 21. The Court emphasised the centrality of a fair trial, observing that the trial Judge, the prosecution and legal aid mechanisms each had responsibilities which were not satisfactorily discharged in this case. The Court, in its reasoning, observed: “In view of the above discussion, the judgments of the Trial Court convicting the appellant of the charged offence and awarding capital punishment and confirmation thereof by the High Court, with particulars as mentioned in Para 1 cannot be sustained and, as such, is set aside. The Appeals are accordingly allowed. The matters are remanded to the Trial Court and restored on the respective docket. The Trial Court shall proceed afresh from the stage of framing of charge. Trial is expedited. It shall proceed, to the extent possible on a day‑to‑day basis. Parties shall appear before the Trial Court on 18th March 2025 and fully cooperate during trial. It is requested that the matter be heard and judgment delivered within a period of one year.” The Court additionally reiterated established principles that “the purpose of trial is to determine the validity of the allegations” and that Article 21 demands procedures which were “right, just and fair and not arbitrary, fanciful or oppressive.”

Background The prosecution’s case was that in the intervening night of 29–30 June 2014 the appellant returned home intoxicated, assaulted his wife Mamta and subsequently killed her and their 12‑year‑old daughter Sapna. Post‑mortem reports recorded multiple ante‑mortem injuries, internal haemorrhage in the mother and head injury in the child. The Trial Court convicted the appellant on 28 February 2017 and sentenced him to death on 1 March 2017; an additional seven years’ imprisonment was imposed under Section 201 IPC. The Allahabad High Court, in Capital Case No.2611 of 2017 and Reference No.05 of 2017, confirmed conviction and sentence on 1 October 2018.

On appeal, the Supreme Court examined a catalogue of trial defects: recording of prosecution star‑witness evidence in the absence of defence counsel and closure of cross‑examination opportunities; repeated and belated changes of court‑appointed amicus/ legal aid counsel; unexplained delay of over a year in framing an additional charge under Section 201 IPC; a summary rejection of an application under Section 311 CrPC; and an improperly recorded Section 313 statement that did not put all material circumstances to the accused. The Court found that the prosecution and trial court had not ensured continuous, effective legal assistance and had not actively guarded the fair‑trial process as required by precedent. The judgment relied on established Article 21 jurisprudence and authorities emphasising that a fair and just investigation and an active judicial role were integral to trial fairness. Given the cumulative procedural infirmities and the real possibility of prejudice, the Court remitted the matter for fresh trial and directed expedited disposal, fixing 18 March 2025 as the day for parties to appear and requesting that the Trial Court endeavour to decide the case within one year.

Case Details: Case No.: CRIMINAL APPEAL NOS.259‑260 OF 2019 (2025 INSC 225) Case Title: Sovaran Singh Prajapati v. The State of Uttar Pradesh Appearances: For the Petitioner(s): Mr. Rajiv Shakdher, Senior Counsel For the Respondent(s): Mr. Divyesh Pratap Singh, Counsel for the State