Case Summary |Ediga Anamma vs. State of Andhra Pradesh

Facts

This case concerns the assassination of a young woman and her infant due to the rage that the accused has generated from sexual envy in a remote town of Andhra Pradesh. In this case, although being married, the accused had a romantic relationship with another guy.

One day her relationship with another guy was caught by her father-in-law and he forced her to leave the house. But the accused continued to have her relationship. Unfortunately, Anusuya the deceased was a neighbour of the accused and married as well. In no time she built an intimate relationship with the accused.

When the accused learned of the love moving towards Anusuya, she was driven by envy and vowed to kill the victim. On the 4th of November 1971 the accused was going to the field to work and she viciously stabbed Anusuya and her daughter aged 10, Nirmala, with a chisel and damaged her face.

At nightfall in a field outside the Village of Konapur, Andhra Pradesh, on the same day. The corpse was found which was of a lady who was the accused as first mistaken, because her face was bruised and clothing was identified on her body belonged to the accused.

The dead body of the baby, Nirmala, the daughter of the dead Anusuya, was retrieved from the bed of a stream in front of a river on 8 November 1971.

 In order to deceive and detect escape, the accused had substituted her clothes with her own. She took the kid away, wrapped it in a fabric piece, and dumped her in the river’s sand. This planning of her worked fine until the village's Patel went down with the accused and unmasked the secret.

It was further proved by the person who made the chisel, approved that the chisel used to kill the deceased belong to the accused as he made it for her. 

Issue:

The accused was charged after additional investigation and conclusions with offences committed in accordance with Sections 302 and 201 of I.P.C. Although there was no immediate grounds of case, prosecution provided a variety of credible evidence, and the lover's additional confession further confirmed the story.

Therefore, the trail court granted her the death penalty and the judgement was also supported by the high court.

The main issue before the Supreme Court was if the accused’s conviction was correct and whether the life imprisonment sentence should be turned into a lesser penalty, i.e., life imprisonment.

Observation by Court: 

The judge at bench stated that, “Unfortunately, there is no penological guidance in the legislation to choose a lower punishment and it is left to ad hoc forensic impressionism to decide for life or death in this confusing case.

Nevertheless, the material of sentencing we were able to save from the guilty material in the paper book persuades us to impose life imprisonment on the offender and to alter the death penalty pronounced by the courts”.

Under Article 367(5) of the Criminal Procedure Code, as amended by Act 26 of 1955, the ordinary rule was that the convicted person of a murder should be sentenced to death and a minor punishment should be imposed on him for reasons which can be recorded in writing.

By modification, it has been deleted, which means that, as opposed to the exception at time when capital punishment was the law and lifetime was the exclusion, the Judiciary wasn’t’ bound and had freedom to reward either capital punishment or lifetime imprisonment for recorded reasons.

In 1973, a major shift overtook the law in the new Criminal Procedure Code. The unmistakable change in legislative emphasis is that according to the rule of law, life imprisonment for killing and the capital punishment is the exception for grounds to be stated.

In this regard it should be pointed out – not definitive, because it is new – that, under the Indian Penal Code (amendment) Bill, 1972 Section 302 of the Penal Code, a less severe clause restricting the death penalty to a few rare situations has been replaced (vide Section 122 of the new Bill).

Held

Justice V.R. Krishna Iyer took a milder attitude throughout the death penalty evaluation. He acknowledged that the death penalty had to be abolished. He also envisaged that, as India advances in the 21st century, human life and dignity must be given priority and therefore the death sentence should be abolished.

He also quoted the Ontario Appeals Court, noting that the death penalty is irrevocable, serious and serious. He also describes the death sentence as "brutal" and "horrible." It's a cold-blooded legal assassination.

In this instance, the Court has ruled that the Court should also consider the status of the accused, apart from examining the facts of the offence. Some key developments were followed by this case.

Section 354(3) was inserted to the 1973 Code of Criminal Procedure which states that the Court must give additional reasons in situations of death punishment. Life imprisonment was an exception earlier, while the death penalty was the opposite.