Machhi Singh vs State of Punjab
1983 AIR 957
Case Summary
[Murder]
[Rarest of the Rare Doctrine]
Facts
A longstanding feud between two families escalated into tragic violence, resulting in 17 deaths (including women and children) and 3 injuries across five villages in Punjab on the night of August 12–13, 1977.
The killings were orchestrated by Machhi Singh and his 11 associates, who targeted the relatives of Amar Singh and his sister, Piaro Bai.
Separate trials were conducted for each village, with Machhi Singh being a common accused across all. The co-accused varied by trial.
Four individuals were sentenced to death, and nine received life imprisonment.
Issues
When should the rarest of rare doctrines be invoked?
Reliability of Eye-Witness Testimonies
Should the doctrine of benefit of doubt be invoked in favour of the accused?
What is the validity of a dying declaration when not done in the presence of a Magistrate ?
Key Legal Provisions
Indian Penal Code, 1860
Section 302 - Punishment for Murder
Rarest of the Rare Doctrine - Established in Bachan Singh vs State of Punjab
Judgement
The Supreme Court upheld the death sentences for Machhi Singh and others based on the application of the "rarest of rare" doctrine. The established guidelines:
The crime must exhibit exceptional depravity or heinousness.
Imprisonment for life should appear inadequate as punishment.
Mitigating circumstances must be given maximum weight, but aggravating circumstances may necessitate a death sentence.
The nature and circumstances of the crime must leave no option but to impose the death penalty.
Furthermore, the remain issues were addressed as the following:
Non-Summoning of magistrate in certain conditions (for example if death is not anticipated), does not invalidate its admissibility of a dying declaration to the police
Where prosecution evidence casts reasonable doubt about an accused's involvement, benefit of doubt must be given. In this case, one accused (Mohinder Singh) received this benefit as evidence linking him to a rifle was weak.
Inhabitants of unelectrified villages are accustomed to seeing under lantern light. Hence, their eyewitness for identification under such conditions was deemed reliable.
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