Mandatory death penalty for life convicts was struck down as arbitrary, unfair, and unconstitutional under Articles 14 and 21.

Section 303 IPC, which mandated death as the only punishment for murder by a life convict, was held unconstitutional because it excluded all judicial discretion and denied consideration of mitigating circumstances, the offence, motive, and surrounding facts. The Court held that this also deprived the accused of a meaningful hearing on sentence under Section 235(2) CrPC and displaced the application of Section 354(3) CrPC, making the sentencing procedure unfair, unjust, and unreasonable under Article 21. The classification of life convicts as a separate class was found arbitrary and unrelated to the object of the provision, violating Article 14. The provision was struck down as void.

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Issues: Whether Section 303 of the Indian Penal Code, 1860, which mandates death as the only punishment for murder committed by a life convict, is unconstitutional as violating Articles 14 and 21 of the Constitution of India.

Analysis: The mandatory death sentence under Section 303 was found to exclude all judicial discretion and to treat life convicts as a separate class without a rational basis. The provision made no allowance for mitigating circumstances, the nature of the offence, the motive, or the surrounding facts, and thereby denied the accused the right to be heard on sentence under Section 235(2) of the Code of Criminal Procedure, 1973, and rendered Section 354(3) of that Code inapplicable. The procedure prescribed was held to be neither fair nor just nor reasonable within Article 21, and the classification was held to be arbitrary and unrelated to the object of the provision, offending Article 14.

Conclusion: Section 303 of the Indian Penal Code, 1860, was struck down as unconstitutional and void.

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