Punjab & Haryana High Court, Chandigarh
CitationAIR 1989 SC 653, (1989) 1 SCC 204
CourtSupreme Court of India (Constitution Bench)
Date16 December 1988
Year1989
BenchR.S. Pathak CJI, E.S. Venkataramiah, Ranganath Misra, M.N. Venkatachaliah, N.D. Ojha JJ.
Acts/ArticlesArticle 72, Article 21, Article 32
CategoryConstitutional Law, Criminal Law

Key Principle Established

Presidential pardon power under Article 72 is wide enough to examine even the merits of the conviction. The President can go into the evidence and re-examine the case.

Brief Facts

Kehar Singh was convicted for conspiracy in the assassination of Prime Minister Indira Gandhi and sentenced to death. After all appeals were dismissed, a petition for presidential pardon under Article 72 was filed. The question arose about the scope and nature of the presidential pardon power.

Ratio Decidendi

The Constitution Bench held that the President’s power under Article 72 is very wide and includes the power to examine the merits of the case, including the evidence. The President is not bound by the views of the judiciary and can form an independent opinion. However, the President acts on the aid and advice of the Council of Ministers.

Impact & Significance

This judgment defined the scope of presidential clemency power in India. It established that Article 72 provides a separate and independent remedy beyond judicial proceedings, and that the President can re-examine the entire case on merits. Read with Epuru Sudhakar (2006), it provides a complete framework for pardon jurisprudence.

Tags & Related Topics

Constitutional Law Criminal Law Article 72 Article 21 Article 32
← Previous Judgment K.M. Nanavati v. State of Maharashtra
Next Judgment → Kesavananda Bharati v. State of Kerala

Related Judgments

1983

D.S. Nakara v. Union of India

AIR 1983 SC 130, (1983) 1 SCC 305

Pension is a right, not a bounty or gratuitous payment. Classification of pensioners into pre- and post-cutoff date categories for…

Read Analysis
2007

Municipal Committee, Patiala v. Model Town Residents Association

(2007) 8 SCC 669

Municipal bodies have a statutory duty to provide basic civic services. Failure to provide water supply, sanitation, and roads is…

Read Analysis
1982

Randhir Singh v. Union of India

(1982) 1 SCC 618

Equal pay for equal work is a constitutional goal derivable from Articles 14, 16, and 39(d) read together.

Read Analysis

Disclaimer

This 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).

Need Case Law Research or Legal Representation?

22+ years of practice before Punjab & Haryana High Court and Supreme Court of India.

Call: +919915442266 WhatsApp

Need Legal Assistance?

Contact Advocate Ravinder Singh Dhull for expert legal guidance on your matter.