The brutal killing of Amravati and Angel, where Deepak Birbahadur Jath was convicted of pouring petrol and setting them ablaze. Initially sentenced to death by the Sessions Court, the Bombay High Court commuted his death sentence to life imprisonment, citing the "rarest of rare" doctrine. The Court considered several mitigating factors, including his potential for reformation, absence of criminal history, and mental health issues, to justify not imposing the death penalty.

1. Incident and Crime Committed:
The incident occurred on April 14, 2017, when the accused, Deepak Birbahadur Jath, poured petrol on Amravati, her daughter Roshni, and a bystander Kanta Eikka with her daughter Angel, setting them ablaze. Amravati and Angel later succumbed to their burn injuries. The police initially registered a case under Section 307 IPC, which was upgraded to Section 302 IPC following the deaths.

2. Trial and Sessions Court Judgment:
Jath was convicted under Sections 302 and 307 of the IPC by the Sessions Court and sentenced to death for the murders of Amravati and Angel, with additional sentences for injuring Kanta. The judgment highlighted the calculated nature of the crime.

3. High Court's Consideration of Sentencing:
The Bombay High Court reviewed whether this case fell under the "rarest of rare" category, warranting the death penalty. Factors such as the accused’s lack of a criminal history, potential for reformation, mental health issues, and remorse were weighed heavily.

4. Medical and Mental Health Reports:
It was observed that the accused had been declared mentally unfit for trial in 2021 but was later declared fit. This factor, along with reports of his stable behavior in jail, played a significant role in the decision to commute his sentence.

Acts and Sections Discussed:

1. Section 302 of IPC - Pertaining to murder, under which the accused was convicted for causing the deaths of Amravati and Angel.
2. Section 307 of IPC - Pertaining to an attempt to murder, under which the accused was convicted for causing severe burn injuries to Kanta.
3. Section 366 of CrPC - Referred for the confirmation of the death sentence from the High Court.

Ratio Decidendi:

The High Court held that while the crime was undoubtedly heinous, it did not meet the stringent "rarest of rare" criteria required for upholding the death penalty. The Court leaned on mitigating factors, including the accused’s mental health, the possibility of reform, and his stable behavior in prison, to justify commutation to life imprisonment.

Subjects:

Criminal law, Murder, Death Penalty, Indian Penal Code, Sentencing

Murder, Life Imprisonment, Rarest of Rare Doctrine, Death Penalty, Criminal Justice, High Court, IPC 302, Sentencing Mitigation