Death Penalty Under BNSS

Understanding the Death Penalty Under BNSS: India’s Legal Landscape

            Written and Paraphrased by Adv. Vipul Singh 

India has a history of opposing international resolutions on the abolition of the death penalty, such as those proposed by the United Nations General Assembly. The death penalty, or capital punishment, has always been a hotly debated issue. On one side, abolitionists argue that it is inhumane and violates basic human rights. On the other, retentionists believe it is necessary to maintain law and order and deter serious crimes. This debate continues to evolve, influenced by modern democratic values and the increasing challenges of crime in society.

This article aims to simplify and analyze key aspects of how death sentences are passed, implemented, and altered in India, especially in light of the Bharatiya Nagarik Suraksha Sanhita (BNSS), a new code proposed to replace the Criminal Procedure Code (CrPC). We will also examine how trial courts and higher courts in India differ in their approach to imposing the death penalty. Contemporary issues, such as the "rarest of rare" doctrine, will also be explored. Finally, some suggestions for improving death penalty jurisprudence in India will be discussed.

Bharatiya Nagarik Suraksha Sanhita (BNSS) 2023 and the Death Penalty

The Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, is India’s new legislation aimed at replacing the colonial-era Criminal Procedure Code (CrPC). While it introduces some procedural updates, it largely retains the framework of the CrPC concerning the death penalty, including its passing, confirmation, and execution. Let’s examine the key provisions related to the death penalty under the BNSS and the safeguards it provides to ensure fairness and justice.

1.1 Passing a Death Sentence

The BNSS, like the CrPC, specifies the courts empowered to pass a death sentence and the conditions they must follow. These provisions aim to safeguard against errors, as a death sentence is irreversible.

Courts Empowered to Pass a Death Sentence

As per Section 22 of the BNSS:

• A High Court has the authority to pass a death sentence.
• A Sessions Judge or Additional Sessions Judge can also pass a death sentence, but it must be confirmed by the High Court before it is implemented.

Further, Section 23 makes it clear that a Chief Judicial Magistrate or any subordinate magistrate cannot pass a death sentence. This strict demarcation ensures that only experienced judges at higher levels of the judiciary handle such serious decisions, minimizing the chances of miscarriage of justice.

Judgment Requirements for Death Sentences

The BNSS has specific provisions governing how judgments involving a death sentence must be delivered.

• Section 393(3): Any judgment that imposes the death penalty must include special reasons explaining why such a sentence is justified. This is a critical safeguard to prevent arbitrary decisions, as the death penalty directly affects the right to life under Article 21 of the Indian Constitution.
• Section 393(5): The judgment must also specify the mode of execution, which remains "hanged by the neck till death" as per Indian law. This method was upheld in the landmark case of Deena v. Union of India (1983), where the Supreme Court ruled that hanging is not unconstitutional as it is a relatively painless and quick method of execution.

Access to Judgment and Appeal Rights

Providing Certified Copies of the Judgment

• Section 404(2): When a death sentence is passed or confirmed by the High Court, the court must provide a certified copy of the judgment to the accused free of cost, even if the accused does not request it. This ensures that the convict is fully informed of the decision and can take steps to challenge it.

Informing the Accused About Appeals

• Section 404(4): If a death sentence is passed, the court must inform the accused about their right to appeal and the time limit for filing the appeal. This is essential because the accused has limited time to act and must be given every opportunity to challenge the decision.

These provisions reflect the principles of fairness and due process, ensuring that the accused has a meaningful opportunity to seek justice.

Case Law References

1. Bachan Singh v. State of Punjab (1980): The Supreme Court laid down the "rarest of rare" doctrine, stating that the death penalty should only be imposed in exceptional cases where the crime is so heinous that it shocks the conscience of society. The doctrine emphasizes that life imprisonment is the rule, and the death penalty is the exception.
2. Machhi Singh v. State of Punjab (1983): The Court elaborated on the “rarest of rare” principle, identifying factors such as the manner of the crime, the motive, and the impact on society while deciding on the death penalty.
3. Mohd. Arif v. Registrar, Supreme Court of India (2014): The Court ruled that cases involving the death penalty require heightened judicial scrutiny, including an open court hearing for review petitions.
4. Shatrughan Chauhan v. Union of India (2014): This case emphasized the rights of death row convicts, ruling that unexplained delays in executing the death sentence could be grounds for commutation to life imprisonment.

Safeguards to Prevent Miscarriage of Justice

The procedural safeguards under BNSS, such as requiring detailed reasoning for death sentences and informing the accused about appeal rights, reflect the judiciary’s commitment to ensuring that the death penalty is imposed only in the most justified cases. These safeguards are rooted in the understanding that capital punishment, being irreversible, demands absolute fairness.

Justice Krishna Iyer, a strong advocate for human rights, famously observed in the case of Rajendra Prasad v. State of Uttar Pradesh (1979) that the death penalty should be imposed sparingly, and the state must justify it with compelling reasons.

1.2 Confirmation of Death Sentence

The process of confirming a death sentence is critical because it ensures that the decision made by the trial court is thoroughly reviewed by a higher authority. Under the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, Chapter XXX (Sections 407–412) deals with the submission and confirmation of death sentences. These provisions are intended to ensure fairness, prevent errors, and protect the rights of the accused.

Submission of Death Sentence for Confirmation

When a Sessions Court sentences a person to death, the case must be reviewed by the High Court under Section 407. The death sentence cannot be carried out until the High Court confirms it. This rule is similar to Section 366 of the CrPC.

Key Points:

• The Sessions Court submits all case records to the High Court for review.
• The High Court examines the evidence, legal reasoning, and overall fairness of the trial.
• Execution of the death sentence is only permitted after the High Court's confirmation.

In State of Punjab v. Kala Ram @ Kala Singh, the Court highlighted that during the confirmation process, the convict is kept in jail under custody for “safe keeping” and not as a form of punishment. The jailor acts as a custodian, not as an enforcer of punishment.

High Court’s Role in Confirmation

Section 408(1): Further Inquiry

If the High Court feels that certain aspects related to the accused’s guilt or innocence need further investigation, it can:

• Instruct the Sessions Court to conduct further inquiries.
• Directly investigate by recording additional evidence itself.

Section 408(2): Presence of the Accused

The accused does not need to be physically present during these proceedings unless the High Court specifically directs otherwise.

Section 408(3): Certification of Findings

When the Sessions Court conducts further inquiries, it must certify its findings and submit them to the High Court for final consideration.

In Balak Ram v. State of Uttar Pradesh, the Supreme Court stressed that the High Court must independently assess all evidence, including evidence presented by the defense. The Court also emphasized the heightened level of caution required in death penalty cases to avoid miscarriages of justice.

High Court’s Powers Under Section 409

When reviewing a death sentence under Section 409, the High Court has the following options:

1. Confirm the Death Sentence: If satisfied with the trial court’s decision.
2. Modify the Sentence: The High Court can reduce the punishment or impose a different legally valid sentence.
3. Overturn the Conviction: The High Court can set aside the conviction, acquit the accused, or order a retrial.

However, the High Court cannot confirm the death sentence until the time limit for filing an appeal has expired, or any pending appeal is resolved.

In Kartarey and Others v. State of Uttar Pradesh, the Supreme Court held that the High Court must carefully re-evaluate all evidence, including additional evidence if presented, to ensure no aspect of the case is overlooked. The Court stressed that the defense's arguments should also be given equal weight in the final decision.

Disagreement Between Judges

Section 410: Decision by a Bench

If the High Court bench consists of two or more judges, at least two judges must agree to confirm the death sentence.

Section 411: Equal Division of Opinion

When there is a disagreement between judges (e.g., one judge supports the death penalty, and another does not), Section 433 provides the procedure to resolve the matter:

1. The case is referred to a third judge who hears the arguments and provides their opinion.
2. The final decision is based on the majority opinion among the judges.
3. If needed, the case can be referred to a larger bench.

In Pankaj Kumar Gupta v. State of Uttar Pradesh, the case was referred to a third judge after a disagreement between two judges on the confirmation of the death sentence. Similarly, in Tanviben Pankajkumar Divetia v. State of Gujarat, the Court resolved differing opinions by referring the matter to another judge.

Communication of the Confirmation Order

Under Section 412, once the High Court confirms or modifies the death sentence, it must send a copy of the order to the Sessions Court.

• The order must be sent promptly, either physically or digitally, to avoid delays.
• A seal and signature by the High Court officer ensure the document’s legitimacy.

This provision reflects an effort to modernize legal processes by allowing electronic communication while maintaining safeguards to ensure authenticity. 

The confirmation process under the BNSS ensures that a death sentence undergoes strict scrutiny by the High Court. This procedural safeguard minimizes the chances of error, as seen in cases like Balak Ram and Kartarey. By requiring thorough re-evaluation of evidence and addressing any disagreements between judges, the process reflects the judiciary’s commitment to fairness and justice, especially in matters of life and death.

1.3 Execution of Death Sentence

Chapter XXXIV A of the Bharatiya Nagarik Suraksha Sanhita (BNSS) (Sections 453–456) deals with how death sentences are carried out after they are confirmed by the High Court. It also covers the suspension, remission, and commutation (reduction) of sentences, including the death sentence.

Execution After Confirmation (Section 453)

Section 453 states that when the High Court confirms a death sentence, the Sessions Court is responsible for ensuring that the death sentence is carried out. The Sessions Court must act on the High Court’s order and make sure the sentence is executed.

• Key Point: After the High Court confirms the death sentence, the Sessions Court must ensure the execution is done.

Issuing the Warrant for Execution (Section 454)

Section 454 provides that if the High Court passes a death sentence, whether in an appeal or revision, the Sessions Court must issue a warrant for execution. A warrant is an official order that instructs the authorities to carry out the death sentence.

• Key Point: The Sessions Court is responsible for issuing the warrant to enforce the death sentence passed by the High Court.

Postponement of Execution (Section 455)

Section 455 deals with situations where the execution of the death sentence may be postponed, especially when the convicted person has the right to appeal to the Supreme Court.

• Section 455(1) says that if the convicted person has the right to appeal to the Supreme Court under Article 134 of the Constitution (for example, appeals related to important legal issues or Constitutional matters), the death sentence cannot be carried out until:
  • The time to file an appeal has passed, or
  • If an appeal is filed, until the appeal is decided by the Supreme Court.
• Section 455(2) further explains that if the convicted person applies for a certificate under Article 132 or Article 134(1)(c) of the Constitution (for example, for special leave to appeal), the execution of the sentence must be delayed until the appeal process is completed.
• Section 455(3) allows the convicted person to apply to the Supreme Court under Article 136 for special permission to appeal. If such an appeal is filed, the execution of the death sentence is delayed until the matter is resolved.
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  Pregnancy and Commutation of Death Sentence (Section 456)
  Section 456 provides special consideration for pregnant women sentenced to death. If a woman is found to be pregnant, the High Court is required to commute (change) her death sentence to life imprisonment.
  This is similar to laws in other countries, like in the United States, where pregnant women are generally not executed, and their sentences are commuted to life imprisonment.
  
  Case Reference:
  In Shatrughan Chauhan v. Union of India (2014), the Supreme Court held that undue delay in executing a death sentence can be grounds for commutation to life imprisonment.
  These provisions aim to ensure that the execution of a death sentence is carried out fairly and in accordance with the rights of the convicted person, giving them opportunities for appeal and providing safeguards like the commutation of sentences in cases involving pregnancy.
  
  

  1.4 Suspension, Remission, and Commutation of Death Sentence

  Section 472 of the Bharatiya Nagarik Suraksha Sanhita (BNSS) deals with the process of mercy petitions in cases where a person has been sentenced to death. This process allows the convict to request a reduction or change in their sentence through petitions to the President of India or the Governor of a State.

  Mercy Petition Process (Section 472)

  • Section 472(1): A convict who has been sentenced to death, or their legal heir/relative, can file a mercy petition to the President of India (under Article 72 of the Constitution) or the Governor of the State (under Article 161 of the Constitution). The petition can be filed within 30 days after the convict is informed that their appeal, review, or special leave to appeal has been dismissed by the Supreme Court or that the death sentence has been confirmed by the High Court.
  • Section 472(2): The mercy petition can first be submitted to the Governor of the state. If the Governor rejects it, the convict can appeal to the President within 60 days from the rejection.
  • Section 472(3): The Superintendent of the jail must ensure that the convict files the mercy petition within 60 days. If the convict doesn't file it, the jail authorities must forward the convict's details and the case records to the Central or State Government along with the mercy petition.
  • Section 472(4): Upon receiving the mercy petition, the Central Government asks the State Government for its comments and considers these along with the case records. The Central Government must then make a recommendation to the President within 60 days from receiving the comments and records.
  • Section 472(5): The President can then consider and decide the mercy petition. If there are multiple convicts in the same case, all their mercy petitions will be decided together in the interest of justice.
  • Section 472(6): After the President makes a decision, the Central Government must inform the State Government and the Superintendent of the jail as soon as possible.
  • Key Point: The decision made by the President or Governor on mercy petitions is final and cannot be appealed in any court.

  Commutation of Death Sentence (Section 474)

  Section 474 grants the government the power to commute a death sentence. This means that the government can change a death sentence to life imprisonment without the convict's consent.
  • Key Point: The death sentence can be changed to life imprisonment by the government, even if the convict does not agree to it.

  Minimum Period of Imprisonment (Section 475)

  Section 475 states that if a person is sentenced to life imprisonment for an offense where the death penalty is a possible punishment, or if a death sentence is commuted to life imprisonment under Section 474, the person cannot be released from prison until they have served at least 14 years.
  • Key Point: Even if a death sentence is changed to life imprisonment, the person must serve at least 14 years in prison before they can be released.

  Concurrent Power of Central Government (Section 476)

  Section 476 grants the Central Government the same powers as the State Government when it comes to death sentences. This means the Central Government can also exercise the powers related to commuting or changing a death sentence, similar to the state authorities.
  • Key Point: The Central Government has the same powers as the State Government regarding the death sentence, which includes commuting the sentence or considering mercy petitions.

  
  

  Case Reference:
  • In Kehar Singh v. Union of India (1989), the Supreme Court clarified that the President's clemency powers under Art. 72 are discretionary and cannot be subjected to judicial review.
  
  These provisions provide a legal framework for seeking clemency, modifying sentences, and ensuring that convicts serve time in proportion to their crimes.

  2. Contemporary Trends on Death Penalty

  The death penalty in India has been a subject of significant debate and legal evolution, especially with the introduction of doctrines and principles by the Supreme Court. One of the key doctrines that guide its application is the “Rarest of the Rare” doctrine.

  Rarest of the Rare Doctrine (Bachan Singh v. State of Punjab)

  In the case of Bachan Singh v. State of Punjab (1980), the Supreme Court introduced the 'Rarest of the Rare' doctrine to limit the use of the death penalty. This doctrine was established to ensure that the death penalty is not imposed in every case, but only in exceptional situations where no other punishment would be adequate.
  • The Court referred to earlier judgments, including Jagmohan Singh v. State of Uttar Pradesh and Rajendra Prasad v. State of Uttar Pradesh, which recognized the death penalty as a violation of the fundamental right to life.
  • However, the Supreme Court held that if a person’s actions pose a significant, continuous, and deliberate threat to society, the state has the constitutional right to take away their right to life by imposing a death sentence.
  The Court clarified that the death penalty is not unconstitutional but must be used only for the rarest of the rare cases, where the crime is so heinous that no other punishment is adequate.

  Guidelines for Determining “Rarest of the Rare” Cases (Machhi Singh Case)

  In Machhi Singh & Ors. v. State of Punjab (1983), the Supreme Court set out the following factors to consider before passing a death sentence:
  1. The way the murder was committed: Was the crime committed in a particularly brutal or inhuman way?
  2. The motive behind the murder: Was there a strong or malicious motive behind the crime?
  3. The anti-social or socially repulsive aspect of the offense: Did the crime shock the societal conscience?
  4. The scale of criminality: Was the crime part of a larger criminal activity?
  5. The characteristics of the murderer: Does the criminal have a history of committing similar offenses?
  These guidelines still guide courts when determining whether to pass a death sentence.

  Inconsistent Sentencing of Death Penalty

  Despite the Supreme Court's efforts to limit the death penalty, there is still inconsistency in how death sentences are imposed across the country. Some courts continue to pass death sentences regularly, while the Supreme Court has been much more hesitant.
  • From 2007 to 2022, the Supreme Court confirmed only 7 death sentences, but trial courts continue to pass many more death sentences, showing a lack of uniformity in sentencing.
  • A report by National Law University Delhi (2022) highlighted that as of December 31, 2022, there were 539 prisoners on death row—the highest number since 2016.
  Despite this increase, the Supreme Court has recently acquitted many death row prisoners, including 55% of the death row cases in 2023. This shows a growing reluctance to uphold death sentences, especially when there are issues like fabricated evidence or manipulated reports.

  Systemic Failures and Issues in Death Penalty Cases

  In the case of Manoj v. State of Madhya Pradesh, the Supreme Court acknowledged systemic failures that lead to unjust death sentences. These include:
  • Fabricated evidence: In some cases, evidence is manipulated or tampered with by the police.
  • Ineffective legal representation: Public pressure, media trials, and political influence often result in poor legal defense for the accused.
  • Flaws in the police and prosecution system: Failures in investigation, such as dubious recoveries of evidence or false reporting, may lead to wrongful convictions.
  The Supreme Court has recognized that these failures affect the fairness of death penalty trials and has proposed reforms to improve sentencing.

  Death Penalty as a Deterrent (Justice Verma Committee)

  The Justice Verma Committee (2013) examined the issue of death penalty, particularly in the context of sexual offenses, such as gang rape. The Committee suggested that the death penalty does not necessarily act as a deterrent to such crimes.
  Despite this, there has been an increase in the number of offenses that attract the death penalty under the BNS (Bharatiya Nagarik Suraksha Sanhita). This creates a conflict between the idea of the death penalty as a deterrent and the fact that it is not always effective in preventing serious crimes.

  Summary

  • Bachan Singh v. State of Punjab and Machhi Singh v. State of Punjab established the "Rarest of the Rare"doctrine to limit the death penalty to the most severe and extreme cases.
  • The Supreme Court has been hesitant to pass death sentences, showing inconsistency in sentencing across courts. This results in a growing number of death row prisoners.
  • Systemic failures in the justice system, such as fabricated evidence and ineffective legal aid, have led to several acquittals by the Supreme Court.
  • The Justice Verma Committee argued that the death penalty is not necessarily a deterrent, especially for crimes like sexual offenses.
  These contemporary trends highlight the ongoing issues and debates surrounding the death penalty in India, with concerns about fairness, consistency, and its effectiveness in deterring crime.

  3. Critical Analysis of the New Criminal Laws in the Death Penalty Context

  The death penalty is a highly controversial issue, and there are strong arguments against its continuation in the BNS (Bharatiya Nagarik Suraksha Sanhita). The death penalty is often seen as a form of retributive justice rather than reformative justice, and there is no clear empirical evidence to support the claim that it deters crime. In fact, some argue that in a democratic society, it is wrong for the state to have the power to take a citizen's life.

  Critique of the BNSS and its Procedural Implications

  • Commutation of Death Sentence: Under Section 474 of the BNSS, there are significant limitations on the power of the government to commute a death sentence. The previous Section 433 of Criminal Procedure Code (CrPC) allowed a death sentence to be commuted to "any other punishment" as prescribed by the Indian Penal Code (IPC). However, the BNSS has restricted the government’s power to commute a death sentence only to life imprisonment.
  • This limitation is seen as an attempt to increase the deterrent effect of the death penalty, but it has serious drawbacks. The accused may not always deserve a harsh punishment, especially in cases where there may be mitigating factors or where the defense was not adequately presented. By limiting the commutation to life imprisonment, the law removes the possibility of a more appropriate, lesser sentence based on the circumstances of the case.
  • Colonial Influence: Although the BNSS seeks to be modern legislation, some provisions still retain a colonial influence. For instance, Section 393(5) of the BNSS states that the death penalty must be executed by hanging. This method was used during the British rule, and while it was believed to be instantaneous, it has since been shown that hanging is often not as humane as it was once thought to be.

  Problems with Hanging as a Method of Execution

  Hanging is believed by some to result in instantaneous death due to the breaking of the neck. However, this is not always the case, and research shows that it can cause extreme suffering before death. Many prisoners experience prolonged suffocation or asphyxiation, which results in a slow and painful death.
  Additionally, there have been numerous documented instances of execution errors:
  • Ropes snapping or necks slipping out of nooses
  • Partial or full decapitations
  • Mechanical failures leading to a botched execution
  These errors demonstrate that hanging, far from being a controlled and humane process, often leads to agony for the prisoner.

  Calls for Alternative Execution Methods

  Even the Supreme Court has questioned the method of hanging. It has urged the Central Government to explore alternative execution methods that are more humane. This includes recommendations for methods that are less painfuland more dignified for the person being executed. For example:
  • The Law Commission of India (2003) suggested amending Section 354(5) of the CrPC to allow for lethal injection as a method of execution, which is generally considered to be less painful and more humane than hanging.
  However, the BNSS 2023 does not address these concerns and continues to uphold hanging as the method of execution, despite the evidence suggesting it causes unnecessary suffering.

  
  

  4. Recommendations and Conclusion

  To improve the fairness and effectiveness of the death penalty system in India, several changes and reforms are needed:

  1. Establishing Sentencing Guidelines

  India should consider establishing guidelines similar to the Sentencing Councils that exist in the United Kingdom. These councils provide a systematic and transparent framework for judges to follow when deciding sentences, especially in complex cases. In India, this framework should help Sessions Courts and High Courts in cases where:
  • The evidence presented by the prosecution is overwhelming, but the defense is unprepared.
  • The influence of media affects the fairness of the trial.
  • The defense counsel fails to provide effective representation or there is a lack of qualified legal aid.
  • There is evidence of bias in the courts, or defense attorneys refuse to represent the accused.
  Having such clear guidelines would help ensure that all cases are handled fairly and in accordance with due process, protecting the rights of the accused while maintaining justice for the victim.

  2. Use of Life Sentences Without Remission

  One significant step toward abolishing the death penalty or reducing its use could be to restrict the early release of life convicts on political grounds. Often, individuals convicted of heinous crimes are released from life imprisonment after a few years due to political influence. To curb this practice, life sentences without remission should be used more frequently, ensuring that convicted individuals remain incarcerated for a longer period without the possibility of release before serving a substantial portion of their sentence.

  3. Clear Definition of 'Rarest of the Rare'

  The 'Rarest of the Rare' doctrine, which the Supreme Court established in cases like Bachan Singh v. State of Punjab, is crucial in determining when a death sentence is justified. However, the definition of what constitutes a 'rarest of the rare' case is still somewhat vague and can be influenced by subjective biases or societal pressures. Therefore, it is important to:
  • Objectively define what makes a case 'rarest of the rare.'
  • Create a transparent framework to guide the courts in deciding when the death penalty should be imposed. This framework should be based on clear criteria, leaving no room for bias or external influence.
  Such a framework would ensure that the death penalty is applied fairly and uniformly, in accordance with the Constitution of India, and in a manner that is consistent with human rights principles.

  Conclusion

  The death penalty continues to be a divisive issue in India, and significant reforms are needed to ensure it is applied fairly and justly. India can improve its criminal justice system by introducing clear sentencing guidelines, reducing the use of the death penalty, and ensuring life sentences are used more effectively. Moreover, a clearer and more objective definition of the 'rarest of the rare' cases will help eliminate any potential bias in death penalty decisions.
  Ultimately, the goal should be to create a justice system that ensures fair trials, protects the rights of all individuals, and balances punishment with rehabilitation. These reforms would help establish a more humane and just legal system in India.

Reference:

1. Life over death: On death penalty abolition and parliamentary panel report, THE HINDU (OCT. 13, 2024. 5:00 PM), https://www.thehindu.com/opinion/editorial/life-over-death-the-hindu-editorial-on-death-penalty-abolition-and-parliamentary-panel-report/article67536304.ece. ↑
2. Vijaita Singh, Parliamentary panel on criminal law Bill leaves decision on death penalty to Centre, THE HINDU (OCT. 14, 2024, 9:10 AM), https://www.thehindu.com/news/national/proposed-criminal-law-increases-number-of-crimes-attracting-death-penalty-from-11-to-15/article67532323.ece. ↑
3. CRIMINAL APPEAL NOS. 248-250 OF 2015. ↑
4. Shailesh Kumar, The continuing distribution of the death penalty, THE HINDU (OCT. 12, 2024, 6:10 PM), https://www.thehindu.com/opinion/lead/the-continuing-distribution-of-the-death-penalty/article68652639.ece. ↑
5. Joseph Mathai et.al., Review Death Penalty Punishments in Bhartiya Nyaya Sanhita 2023, PEOPLE'S UNION FOR DEMOCRATIC RIGHTS, (OCT. 12, 2024, 5 PM), https://www.pudr.org/press-statements/review-death-penalty-punishments-in-bhartiya-nyaya-sanhita-2023/. ↑
6. Abdul, SC Bench seeks data on alternatives to hanging, FORUMIAS, (OCT. 12, 2024 6 PM), https://forumias.com/blog/sc-bench-seeks-data-on-alternatives-to-hanging/. ↑