Review of Death Penalty XXII

Mofil Khan v. State of Jharkhand, [Review Petition (Criminal) No. 641 of 2015 in Criminal Appeal No. 1795 of 2009] has observed, possibility of reformation and rehabilitation of convict is an important factor which has to be taken into account as a mitigating circumstance.

It is also our duty to take into consideration, state of mind of criminal and his socio-­economic conditions. This is a first offence committed – no doubt, a heinous one. It cannot be said, there is no possibility of being reformed and rehabilitated. Death Sentence is converted to Life Imprisonment for 30 years.

Hon’ble Justice B.R. Gavai, Bhagchandra v. State of Madhya Pradesh, [Criminal Appeal Nos. 255-256 of 2018].


Also see, Bhagwani v. State of Madhya Pradesh, [Criminal Appeal Nos. 101-102 of 2022] decided on 18.01.2022.