In which one of the following judgments of the Constitutional Bench of the Supreme Court of India, the ‘rarest of rare’ principle in the award of death penalty was first laid down ?

The 'rarest of rare' principle was first established by a five-judge Constitution Bench of the Supreme Court in the landmark case of Bachan Singh v. State of Punjab (1980) [2]. In this judgment, the Court upheld the constitutional validity of the death penalty under Section 302 of the Indian Penal Code, ruling that it does not violate Article 21 of the Constitution [2]. The Court emphasized that life imprisonment is the rule and the death penalty is an exception, to be awarded only in 'rarest of rare' cases where the alternative option is unquestionably foreclosed [1]. Other cases mentioned, such as Tukaram v. State of Maharashtra (1979), pertain to different legal issues like custodial rape [4]. Bachan Singh remains the foundational authority for capital punishment sentencing in India, requiring courts to balance aggravating and mitigating circumstances [3].

Sources

1. [2] Indian Polity, M. Laxmikanth(7th ed.) > Chapter 90: Landmark Judgements and Their Impact > BACHAN SINGH CASE (1980) > p. 628
2. [1] Indian Polity, M. Laxmikanth(7th ed.) > Chapter 90: Landmark Judgements and Their Impact > BACHAN SINGH CASE (1980) > p. 629
3. [4] https://www.jstor.org/stable/4404561
4. [3] https://blogs.law.ox.ac.uk/death-penalty-research-unit-blog/blog-post/2025/05/exploring-punitive-populism-and-performative