In the manoharan vs state by inspector of police decision, the petitioner Manoharan was found guilty and given the death penalty. However, the petitioners’ review requests were dismissed by the Supreme Court of India. In accordance with Section 302, 376(2)(f) and (g), and section 201 of the indian penal code, the court upheld Manoharan’s conviction.
manoharan vs state by inspector of police Case Facts
- Manoharan, the petitioner in this case, was found guilty in several sections of the Indian Penal Code (IPC) for his participation in a horrific crime that happened on October 29, 2010.
- This particular case concerned the kidnapping, sexual assault, and demise of a boy and a girl who attended school. Following the discovery of the kids’ remains in a canal, Manoharan and another suspect were taken into custody.
- Circumstantial evidence, such as Manoharan’s confessional statement, which he later withdrew during the trial, formed the foundation of the prosecution’s case. He was found guilty by the trial court, and the execution order was confirmed by the High Court.
- Manoharan challenged the High Court’s ruling in an appeal that was submitted to the Supreme Court. The admission of confessional remarks, the adequacy of legal representation, and the applicability of other IPC provisions, such as section 376 of the indian penal code (relating to rape), were among the legal questions raised by the case.
- The Supreme Court upheld Manoharan’s conviction for a number of violations after reviewing the evidence and taking legal arguments into consideration. The case called into question the proper application of the death penalty in some circumstances, the criteria for legal representation, and the use of confessions in criminal prosecutions.
manoharan vs state by inspector of police Issues
- Manoharan’s confessional declaration and its subsequent reversal raised a number of important questions. The confession’s voluntariness and reliability, as well as whether its credibility was impacted by its retraction, had to be decided by the court.
- The petitioner contended that he had not been provided with sufficient legal counsel, casting doubt on his entitlement to efficient legal aid as per Article 21 of the Indian Constitution. The petitioner’s access to adequate legal aid counsel was a matter for the court to determine.
- The case brought up the question of whether the petitioner’s convictions under several Indian Penal Code (IPC) sections, including Section 376, which deals with rape, were supported by the evidence that was given.
- Considering the circumstances of the crime, the petitioner’s involvement, and the existence of mitigating circumstances, the court had to decide if the death penalty should be applied.
- A large amount of circumstantial evidence was used in this case. From the circumstantial evidence that was offered, the court had to decide if the prosecution had proven the defendant’s guilt beyond a reasonable doubt.
- The petitioner contested the application of revisions to the POCSO Act retroactively in imposing the punishment. The question of whether these revisions applied in this case, which was filed before the amendments, had to be addressed by the court.
Contentions by the Parties
Petitioner:
For a number of reasons, the petitioner disputed his conviction and death penalty.
- First, he claimed that he was coerced into making a confessional statement, not something he voluntarily did. He said that the cops had forced him into making the confession.
- Second, the petitioner claimed that his constitutional right to competent legal counsel was violated by the lack of representation he received during the trial. He claimed that the legal assistance attorney assigned to represent him was not adequate.
- Thirdly, he argued that the confessional testimony pointed to a distinct offense under Section 377 of the IPC, and that he had been wrongfully convicted under section 376 of the indian penal code. He also disputed the use of circumstantial evidence to support his conviction, claiming that there were inconsistencies and uncertainties in the case.
- Lastly, he claimed that it was illegal to apply revisions to the pocso act retroactively in order to determine his sentence.
Respondent:
- The petitioner’s voluntary and trustworthy confessional declaration was upheld by the state, which was represented by the Inspector of Police from Variety Hall Police Station in Coimbatore.
- They maintained that there had been no threats or coercion used to get the statement.
- The state further argued that the petitioner’s legal assistance counsel provided sufficient legal representation throughout the trial.
manoharan vs state by inspector of police Judgment
- In the Manoharan v. State decision, the petitioner Manoharan was found guilty and given the death penalty. However, the petitioners’ review requests were dismissed by the Supreme Court of India. The court upheld Manoharan’s conviction in line with Section 302, 376(2)(f) and (g), as well as section 201 of the indian penal code.
- The petitioner brought up a number of important points, which the court examined. These included the appropriateness of his legal representation, the voluntariness of his confessional statement, and the retroactive application of modifications to the Protection of Children from Sexual Offenses (POCSO) Act.
- The petitioner’s objections were dismissed by the court, which determined that the pocso act’s changes could be used in this case, the confession was voluntary, and he had sufficient legal counsel.
- The court further underlined how horrific and horrible the petitioner’s crimes, which included kidnapping, raping, and killing two school-age children, were. The court decided that these crimes qualified as the rarest of the rare, which made the death punishment appropriate.
manoharan vs state by inspector of police: Dissenting Judgment
- Judge Sanjeev Khanna sentenced Manoharan to life in jail without the possibility of parole or commutation until the time of his natural death, despite the fact that his conviction was upheld. Khanna felt that the majority’s decision was erroneous.
- Justice Khanna expressed in his dissenting opinion that the confession’s retractions should be understood as an afterthought or advice motivated by fear that the appellant (Manoharan), given his admission, might be hanged and that his previous confession, in which he begged for forgiveness, would be the reason for his demise.
- The author states that it is impossible to rule out that the feeling of regret, repentance, and forgiveness would not be valued and given the proper consideration, which is why this mistrust and attempt to withdraw had developed. Justice Khanna stated that the retraction should not be used as proof in Manoharan’s case.
- When evaluating the mitigating factors in Manoharan’s favour, Justice Khanna also took into account the fact that Manoharan was a first-time offender. It was his 23rd birthday when the crime was perpetrated. He was reared by his aging parents in a low-income household. The architect of the crime was his companion Mohanakrishnan, who was later slain in a meeting with the police.
- Mohanakrishnan came up with, created, and carried out the plan to abduct the kids all by himself. The appellant followed him and was present with Mohanakrishnan after that. This caused Mohanakrishnan’s evil side to emerge, and as a result, he raped and sexually tormented the young girl while the appellant remained silent. The appellant then suffered from a rape and a sexual assault. The kids were then shot with poison just before being thrown into the canal.
- Despite calling the crime vile and abhorrent, the judge decided not to execute the offender in this instance.
After giving serious thought, the Supreme Court of India dismissed the petitioner Manoharan’s review petitions in the Manoharan v. State case. The court affirmed its previous ruling to sustain Manoharan’s conviction in accordance with Indian Penal Code Sections 302, 376(2)(f) and (g), and 201.
The verdict upheld the court’s conclusions on a number of matters, such as the suitability of Manoharan’s legal counsel, the voluntariness of his confessional testimony, and the retroactive application of POCSO Act modifications. The court decided that the changes may be used in this case, the confession was made voluntarily, and there was sufficient legal assistance.
Crucially, the court emphasized how horrific Manoharan’s crimes, involving the kidnapping, rape, and murder of two defenceless schoolchildren, were. The death penalty was justified by the court’s unwavering declaration that these acts constituted the rarest of the rare situations.
The Supreme Court steadfastly affirmed its earlier ruling, upholding Manoharan’s conviction and the death penalty. The ruling highlighted the seriousness of the crimes and the need for a strong legal reaction in such horrible circumstances to guarantee justice and serve as a deterrent.
Only the most horrible crimes, those that gravely disturb social harmony, should result in a person’s execution. Everyone in the nation is devastated by the news of the rape and murder of a ten-year-old boy and girl. Such crimes are not committed in a split second; rather, they need a great deal of forethought and preparation. It is important that prisoners have the right to appeal their convictions, but lawmakers must strike a compromise between the severity of the punishment and the execution of the guilty.
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