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.