Aman Singh & Anr. {Appellant} Vs. State of Bihar {Respondent}
CRIMINAL APPEAL NO(S). OF 2026
(Arising out of SLP (Criminal) No(s). of 2026)
(Diary No(s). 24574 of 2026)
(Three Judge Bench, Before Vikram Nath, Sandeep Mehta and Vijay Bishnoi, JJJ.)
Overview
In this case, the Supreme Court had to deal with the appeals from a death sentence confirmed by the Patna High Court. During the proceedings, the execution of the appellants was stayed by the court.
The Court had to address a larger issue as to how the death penalty cases are handled in India. It was observed that many cases suffer from lack of attention towards the circumstances, background of the accused, or conduct in jail before awarding capital punishment.
The Court therefore, used this matter to issue proper directions to Trial Courts, High Courts, and Legal Services Authorities to ensure a fair sentencing process in all death penalty matters to be dealt in the future.
Facts of the Case
The appellants in this case, Aman Singh and Sonal Singh, were sentenced to death being convicted in a criminal case. This was later confirmed by the Patna High Court on 22 January 2026 through Death Reference No. 2 of 2024 along with Criminal Appeal (DB) No. 691 of 2024. Following the same, the matter reached the Supreme Court through criminal appeals, which were filed by the appellants. During this time, both the appellants were lodged in Buxar Jail, Bihar.
The case thereafter was considered by the Court, not only on the question of confirming the death sentence, but also on the larger issue pertaining to the matter in which mitigating and aggravating circumstances are considered when it comes to cases of capital punishment.
Legal Issues
- Whether the Trial Courts and High Courts are required to call for mitigation reports before confirming capital punishment.
- Whether not having rules and regulations for the assessment of mitigating circumstances, affects fairness in death penalty cases.
- Whether improper legal representation affects sentencing in death penalty matters.
- Whether mitigation specialists should be allowed confidential access to convict’s information for their assistance.
- Whether it is mandatory for Legal Services Authorities to provide specialised legal assistance in capital punishment cases.
Decision
The Supreme Court granted leave and the execution of the death sentence was stayed until further proceedings.
The Court noted that relevant material as to the social background, conduct, possibility of reformation, and mental health of the appellants had not been placed before the cou at the initial stages of the case.
To address the same, the state authorities were directed to produce the reports and relevant data concerning the same before the Court. It also permitted mitigation specialists from the Square Circle Clinic at NALSAR University of Law to conduct interviews with the applicants in a completely confidential manner.
Further issuing general directions for future capital punishment matters, The Court held that trial courts must call for reports pertaining to aggravating and mitigating circumstances before imposing sentences and in the absence of such reports, it is the responsibility of the High Court to obtain them during death reference proceedings.
Both, Legal Services Authorities as well as NALSAR were directed to frame proper guidelines when it comes to collection of mitigating circumstances and rehabilitation related material to assist the courts in conducting a proper sentencing process. The matter was directed to be listed after 20 weeks.
