The Supreme Court reviewed the death sentence awarded to the appellant, who was convicted of murdering his pregnant daughter in an apparent honor killing due to her inter-caste marriage. After examining both the aggravating and mitigating circumstances, including the appellant's health, mental condition, and socio-economic background, the Court commuted the death sentence to 20 years of rigorous imprisonment without remission, concluding that it was not a “rarest of rare” case warranting capital punishment.

• Facts: Eknath Kisan Kumbharkar was convicted for the murder of his pregnant daughter, Pramila, because she had married against his wishes. He strangled her with a rope in an auto-rickshaw after convincing her to come with him under the false pretext of meeting her ailing grandmother. The trial court sentenced him to death, which was confirmed by the Bombay High Court.

• Defense: The defense argued that the prosecution failed to prove a clear motive and raised doubts about the reliability of eyewitness testimony, particularly from PW2 (auto driver), and the non-examination of material witnesses. They also pointed to discrepancies in testimonies and financial disputes between the accused and PW2.

• Prosecution: The prosecution successfully established the appellant's guilt, showing that he held a grudge against his daughter for tarnishing his reputation by marrying outside the caste. The evidence of PW1, PW2, and PW3 corroborated the prosecution's case that the appellant premeditated and executed the crime.

• Supreme Court Findings: While the Supreme Court upheld the conviction under Sections 302, 316, and 364 of the IPC, it reduced the death sentence, citing mitigating factors such as the appellant's age (38 at the time of the crime), lack of prior criminal record, poor socio-economic background, and his current mental and physical condition.

• Ratio Decidendi: The Court held that the case did not meet the threshold of the "rarest of rare" category, which is a prerequisite for the death penalty. The appellant’s potential for reformation and his health conditions were critical factors leading to the reduction of his sentence.

1. Background of the Case:

   • Pramila, the appellant's daughter, married outside her caste in 2013. This marriage led to a rift between her and her father, the appellant.

2. Incident Leading to the Crime:

   • On 28/06/2013, the appellant took Pramila from her home under the pretext of visiting her grandmother, who was allegedly ill. He strangled her in an auto-rickshaw, witnessed by PW2 (the auto driver).

3. Conviction and Sentencing:

   • The trial court convicted the appellant for murder and sentenced him to death. The Bombay High Court upheld this judgment.

4. Appeal and Defense Arguments:

   • The defense questioned the reliability of eyewitnesses, non-examination of material witnesses, and suggested a financial dispute between the appellant and PW2, aiming to show false implication.

5. Supreme Court’s Examination of Evidence:

   • The Court affirmed the reliability of key prosecution witnesses (PW1, PW2, PW3) and found no merit in the defense's arguments regarding motive and false implication.

6. Mitigating Circumstances:

   • The appellant's poor socio-economic background, lack of criminal history, mental and emotional disturbances, and prison behavior were highlighted as factors warranting leniency in sentencing.

7. Conclusion and Sentence Modification:

   • The Supreme Court modified the death sentence to 20 years of rigorous imprisonment without remission, acknowledging the possibility of reformation.

Acts and Sections Discussed:

• Indian Penal Code (IPC) Sections:
  • Section 302: Punishment for murder.
  • Section 316: Causing death of a quick unborn child by an act amounting to culpable homicide.
  • Section 364: Kidnapping or abducting in order to murder.

Ratio Decidendi:

The case did not meet the criteria for the "rarest of rare" doctrine essential for upholding a death sentence. The mitigating factors, such as the appellant’s mental health, age, socio-economic circumstances, and behavior in prison, indicated that there was potential for reformation, leading the Court to impose a lesser sentence.