Advocate Bhuvnesh Kumar Goyal

Rajasthan High Court Jaipur Commutes Death Sentence to Life Imprisonment Till 75

Jaipur: The Rajasthan High Court, Jaipur Bench, has declined to confirm the death sentence awarded to Pintu Dagar, who was convicted of murdering his wife and six-month-old son in Kota in June 2021. While upholding his conviction, the Division Bench directed that he undergo rigorous imprisonment for life until he attains the age of 75 years, without the benefit of statutory remission.

The judgment was delivered on October 3, 2026, by a Division Bench comprising Justice Mahendar Kumar Goyal and Justice Praveer Bhatnagar.

The Court was examining a death reference submitted by the trial court for confirmation of the capital punishment, along with the criminal appeal filed by the convict challenging his conviction and sentence.

Court Upholds Conviction Based on Evidence

According to the prosecution, the incident occurred on June 1, 2021, in Kota. The accused was alleged to have murdered his wife, Seema, and their infant son, Avinash alias Rajvir.

The prosecution relied on the testimony of witnesses who stated that they had seen the accused dragging his blood-soaked wife by her hair while carrying an axe. The Court also considered the recovery of the weapon, bloodstained clothes, forensic evidence and DNA analysis.

The High Court observed that the prosecution had established the chain of circumstances connecting the accused with the crime beyond reasonable doubt. It found no sufficient ground to interfere with the trial court’s finding of guilt and accordingly maintained the conviction for murder.

Death Penalty Not Justified Merely Because the Crime Was Heinous

The principal question before the High Court was whether the case fell within the category of the “rarest of the rare” cases warranting capital punishment.

The Bench reiterated that the gravity and brutality of a crime, by themselves, cannot be the sole basis for imposing the death penalty. Courts must carefully balance the aggravating circumstances against the mitigating circumstances and determine whether the alternative of life imprisonment is unquestionably foreclosed.

In reaching its conclusion, the Court considered the absence of an established motive, the circumstances surrounding the incident, the accused’s personal and socio-economic background, his conduct in prison and the material concerning his potential for reformation.

The Court noted that the prosecution had not established that the murders were pre-planned or cold-blooded. The evidence indicated that the accused and his wife had been married for approximately 15 years and had two sons. The prosecution was unable to establish what had transpired between the couple in the period preceding the incident.

The Bench emphasised that even in a grave double-murder case, the death penalty cannot be imposed without applying the constitutional principles governing capital sentencing.

Importance of Supreme Court Guidelines on Sentencing

The judgment discusses the principles laid down by the Supreme Court in Bachan Singh v. State of Punjab, Machhi Singh v. State of Punjab and Manoj v. State of Madhya Pradesh, among other decisions.

The Bench also considered the Supreme Court’s directions in Aman Singh and Another v. State of Bihar concerning the collection and assessment of material relating to aggravating and mitigating circumstances in death penalty cases.

Such material may include the convict’s family history, education, socio-economic circumstances, criminal antecedents, psychological and psychiatric assessments, prison conduct and prospects of rehabilitation.

The High Court examined the reports placed before it, including the prison conduct report and psychiatric evaluation. The records indicated satisfactory and peaceful conduct in custody, while the psychiatric assessment did not identify a gross psychiatric disorder.

The Court also considered the circumstances of the convict’s surviving elder son, who was being cared for by his grandparents, and the family’s limited financial resources.

Life Imprisonment Until the Age of 75

After weighing the aggravating and mitigating circumstances, the Bench concluded that the case did not meet the legal threshold for the “rarest of the rare” category.

However, the Court did not consider ordinary life imprisonment subject to the usual remission framework to be the appropriate sentence in the circumstances. Referring to the principles governing special-category life sentences, including those discussed in Swamy Shraddananda v. State of Karnataka and Navas alias Mulanavas v. State of Kerala, the Bench ordered rigorous imprisonment for life until the convict attains the age of 75 years, without the benefit of statutory remission.

The Court consequently answered the death reference in the negative and partly allowed the criminal appeal only to the extent of modifying the sentence. The conviction and fine imposed by the trial court were maintained. The best lawyer in jaipur, have commended and welcomed the order of the honourable Rajasthan High Court, Jaipur

Key Legal Takeaway

The ruling underscores an important distinction in criminal sentencing: upholding a conviction for a heinous offence does not automatically justify the death penalty. Even where guilt is established beyond reasonable doubt, the court must independently assess the appropriate punishment in accordance with the principles of proportionality, the balance between aggravating and mitigating circumstances, and the possibility of reformation.

The judgment reinforces the requirement that capital punishment be reserved for cases in which the alternative of life imprisonment is unquestionably foreclosed, while recognising that courts may, in appropriate cases, impose a special-category life sentence for a specified period without statutory remission.

Read the complete order here