‘Possibility Of Reformation Can’t Be Ruled Out’: Supreme Court Reduces Death Sentence Of Man Convicted For Sexual Assault And Murder Of 4-Year-Old

Aastha Pareek 

On December 17, 2024, the Supreme Court of India commuted the death sentence in the case of Sambhubhai Raisangbhau Padhiyar v. State Of Gujarat wherein the man was convicted for the sexual assault and murder of a four-year-old child. The Court emphasized that the potential for his reformation cannot be entirely disregarded.  

The Bench, comprising of Justices B.R. Gavai, Aravind Kumar, and K.V. Viswanathan, upheld the man’s conviction under Sections 302 (murder), 364 (kidnapping), and 377 (unnatural offences) of the Indian Penal Code, as well as Sections 4 and 6 of the Protection of Children from Sexual Offences (POCSO) Act. However, they reduced his death sentence to 25 years of imprisonment without remission, emphasizing that the possibility of his reformation could not be entirely dismissed. 

The case involved the abduction of a four-year-old child under the pretense of buying ice cream, followed by sexual assault and murder by strangulation. Key evidence included testimony from the child’s aunt, who witnessed the accused taking the child, and forensic findings that linked the accused to the crime scene. 

In reconsidering the death penalty, the Court reviewed several reports assessing the convict’s mental and behavioral state. A ‘Mitigation Investigation Report’ indicated that the convict exhibited moderate psychotic features and intellectual disability, possibly stemming from childhood tuberculosis meningitis. Additionally, reports from the Superintendent of Vadodara Central Jail and the Hospital for Mental Health described his behavior in prison as normal, with no current psychiatric issues, and noted expressions of remorse. 

The Court concluded that, given these assessments, the chance for the convict’s reformation could not be entirely ruled out. Consequently, they deemed a 25-year imprisonment without remission to be an appropriate sentence, aligning with the principles of restorative justice. 

This decision underscores the Supreme Court’s commitment to balancing justice for heinous crimes with the potential for rehabilitation, reflecting a nuanced approach to capital punishment in India.

Case Name:- Sambhubhai Raisangbhau Padhiyar v. State Of Gujarat

Case Number:- Criminal Appeal Nos. of 2024 (@ Special Leave Petition (Crl.) Nos. 9015-9016 of 2019)

Bench:- Justices B.R. Gavai, Aravind Kumar, and K.V. Viswanatha

Click here to access the order.