Law & Justice · September 2026

23 Death Sentences in 5 Months.

A single sessions judge in Muzaffarnagar, Uttar Pradesh sentenced 23 people to death in approximately five months. The Supreme Court has very clear rules about how death sentences must be imposed. Less than 4% of trial court death sentences since 2022 follow those rules. This is not a small procedural problem. It is a constitutional crisis hiding in courtrooms.

A death sentence is the most irreversible act a court can perform. It ends a life. Once carried out, no appellate judgment can undo it. For this reason, the Supreme Court of India has built, over decades, a careful architecture of procedural safeguards — specific requirements that a court must satisfy before it condemns a person to death. These are not suggestions. They are binding law.

Between approximately February and July 2026, the Additional District and Sessions Judge (ADJ) in Muzaffarnagar, Uttar Pradesh handed down death sentences to 23 people across nine separate judgments. The sentences were imposed in roughly five months.

Researchers at NALSAR University of Law examined those nine judgments carefully. What they found should concern every person who believes that the law means what it says — regardless of their views on capital punishment.

What the Supreme Court Requires Before a Death Sentence

To understand what went wrong in Muzaffarnagar, you first need to understand what the law requires. Indian law on the death penalty has evolved through a series of landmark Supreme Court judgments that have progressively made the process more rigorous and individualised.

For decades after Bachan Singh, there was a gap between the law’s requirement and courtroom practice. Mitigation — the investigation of an accused person’s background, mental health, and social circumstances — was often reduced to the judge asking the accused at sentencing whether they had “anything to say.” The accused usually said nothing meaningful. The judge moved on. Bachan Singh’s requirement of individualised assessment became, in practice, a formality.

Manoj v. State of MP (2022): The Game-Changing Judgment

In May 2022, the Supreme Court issued a landmark judgment in Manoj v. State of Madhya Pradesh that tried to fix the gap between the Bachan Singh standard and actual practice. The court laid down a detailed, mandatory procedural framework that every trial court must follow before imposing death.

Then, in August 2025, the Supreme Court reinforced the Manoj v. State of Madhya Pradesh framework in Vasanta Sampat Dupare v. Union of India. The court held explicitly that imposing a death sentence without following the safeguards mandated in Manoj v. State of Madhya Pradesh would be a violation of the accused’s fundamental rights — not merely a procedural irregularity, but a constitutional violation.

What the Muzaffarnagar Judgments Actually Show

Against this legal background, researchers examined the nine Muzaffarnagar death sentence judgments. Their findings are striking — not because the trial judge ignored Supreme Court precedents, but because he cited them extensively while ignoring what they actually require.

The judgments repeatedly cite the same set of Supreme Court cases — including Bachan Singh — in much the same sequence, often using the same excerpts. The citations are there. The reasoning is not.

When the judgments come to the actual decision — should this person be sentenced to death or to life imprisonment — the reasoning rests almost entirely on the nature and circumstances of the crime. The crimes are described in detail. Their brutality is documented. The offences are characterised as heinous. Death is imposed.

What is absent from the judgments is any indication that the Manoj v. State of Madhya Pradesh framework was followed. There is no evidence that probation reports, prison authority reports, psychological assessments, or mitigation reports were obtained or considered. There is no individualised examination of who the accused persons are — their backgrounds, mental states, histories, or possibilities of reform. The law as laid down by Bachan Singh and reinforced by Manoj was, in the key moment, simply not applied.

The National Picture: Only 4% Compliance

The Muzaffarnagar cases are troubling. The national data is alarming.

Read that again. After the Supreme Court issued a detailed, specific, mandatory framework for how death sentences must be imposed — a framework it later elevated to the status of a fundamental right requirement — over 96 percent of trial courts that imposed death sentences in the following three years simply did not follow it.

This is not a few judges making isolated errors. This is a near-total systemic failure to implement a binding Supreme Court precedent in the highest-stakes legal context that exists. It raises profound questions about how India’s trial courts understand their relationship to Supreme Court authority.

What Happens to These 23 People Now?

Under Indian law, every death sentence imposed by a trial court must be confirmed by the relevant High Court before it can be carried out. This is called the “confirmation” process. The High Court reviews the case afresh — it examines both the conviction and the sentence independently, and it has the power to uphold, modify, or set aside the death sentence.

Virtually none of the 23 Muzaffarnagar death sentences will ultimately be upheld, precisely because they do not comply with the Manoj v. State of Madhya Pradesh framework. The Allahabad High Court will review them, find the Manoj v. State of Madhya Pradesh requirements unmet, and will be obliged to reject the sentences as constitutionally invalid.

But this will take years. The 23 people condemned in those Muzaffarnagar courtrooms will spend those years under the shadow of a death sentence that was almost certainly going to be overturned from the moment it was imposed. They will wait. Their families will wait. The legal process will grind on.

The Bigger Problem: What These Cases Reveal About the System

The Muzaffarnagar judgments, and the NALSAR data behind them, point to three distinct but interconnected failures.

First: A failure of legal training. If more than 96 percent of death sentence judgments are non-compliant with a four-year-old Supreme Court precedent, something has failed in how that precedent is being communicated to and absorbed by trial courts. The Manoj judgment is not obscure or difficult — it is one of the most discussed Supreme Court rulings of recent years. Trial judges who impose death sentences should know it and apply it. That most apparently do not suggests a systemic gap in judicial training and oversight.

Second: A conflation of crime and criminal. The temptation in severe cases is obvious. A crime has been committed that shocks the conscience. A judge who lets the horror of the crime dominate the sentencing reasoning is, in human terms, understandable. But it is legally wrong. The Bachan Singh standard exists precisely because the severity of a crime is not, by itself, sufficient justification for killing the person who committed it. A judge who sentences on the basis of crime severity alone — however egregious the crime — is not applying the law. They are substituting their moral reaction for it.

Third: A confusion about what judicial independence means.  Judicial independence cannot and does not mean judicial freedom from the law. A trial court judge has independence from external political or personal pressure. They do not have independence from binding Supreme Court precedent. The law laid down in Bachan Singh, Manoj, and Dupare is not optional. It is not something a trial judge can decide to weigh against their own philosophy of punishment. It is binding.

It means not the courage to impose a death sentence when a crime is horrible — that, in fact, requires very little courage, because the public and the judge’s own instinct may support it. The real courage is in following the law even when it demands more from you, even when it complicates the obvious response, even when it requires you to look at the person who committed the crime and not just at what they did.

Twenty-three people in Muzaffarnagar are currently under death sentences that were almost certainly imposed in violation of the Constitution. They will probably not be executed. But they will wait, for years, for the appellate process to confirm what the law already says. That is not justice. That is a legal system failing to keep its own house in order.