भारत के महान्यायवादी बनाम लछमा देवी
| Citation | AIR 1986 SC 467 |
| Court | Supreme Court of India |
| Date | 13 December 1985 |
| Year | 1986 |
| Bench | P.N. Bhagwati CJ, D.P. Madon, G.L. Oza JJ. |
| Acts/Articles | Article 21 |
| Category | Constitutional Law, Criminal Law |
Key Principle Established
Execution of death sentence by public hanging is barbaric, inhuman, and violative of Article 21. Public hanging is unconstitutional regardless of any Jail Manual provision.
The Rajasthan High Court ordered execution of a death sentence by public hanging at the Stadium Ground or Ramlila Ground of Jaipur with widespread publicity. The Attorney General of India challenged this order before the Supreme Court.
The Supreme Court held that public hanging is barbaric, inhuman, and degrading — it violates Article 21 which guarantees the right to life and personal liberty with dignity. Even if any Jail Manual provided for public hanging, such a provision would be unconstitutional.
This judgment established that even persons sentenced to death retain their right to dignity under Article 21. The mode of execution must not be cruel, inhuman, or degrading. This reinforced India’s commitment to humane treatment even in the administration of the ultimate punishment.
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Read AnalysisThis judgment summary is for educational and research purposes. While care has been taken to accurately represent the ratio and findings, for authoritative reference always consult the original judgment text from official sources (SCC Online, AIR, Manupatra, or court websites).
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