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← Index: Important Supreme Court Judgments — One-LinersChapter 15
Study Guide · Chapter 15

M. Selected Additional Landmark Cases

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Case Year Bench Holding
Bachan Singh v. State of Punjab 1980 5-judge Upheld the constitutional validity of the death penalty for murder, but confined its imposition to the "rarest of rare" cases where the alternative of life imprisonment is unquestionably foreclosed.
Machhi Singh v. State of Punjab 1983 3-judge Elaborated Bachan Singh's "rarest of rare" test into concrete categories (manner of commission, motive, social abhorrence, magnitude, and the victim's identity/status) to guide when a murder crosses the threshold for death sentence.
Mithu v. State of Punjab 1983 5-judge Struck down the mandatory death sentence prescribed under Sec. 303 IPC (for murder by a life convict) as arbitrary and unconstitutional — sentencing discretion cannot be removed entirely from judges.
T.M.A. Pai Foundation v. State of Karnataka 2002 11-judge Defined the autonomy private and minority educational institutions enjoy over admissions and fee structures under Arts. 19(1)(g) and 30, while permitting reasonable regulatory oversight to ensure merit and prevent profiteering.
P.A. Inamdar v. State of Maharashtra 2005 7-judge Held the State cannot impose its reservation policy on unaided private professional institutions — a ruling later substantially modified in effect by the 93rd Constitutional Amendment.
Aruna Ramchandra Shanbaug v. Union of India 2011 2-judge First recognised a limited, tightly-conditioned form of passive euthanasia in India (withdrawal of life support for a patient in a permanent vegetative state, with High Court oversight) — the framework was later broadened and formalised by Common Cause (2018).
Lily Thomas v. Union of India 2013 2-judge Struck down the statutory provision that let a convicted sitting MP/MLA continue in office pending appeal — held disqualification under the Representation of the People Act takes effect immediately upon conviction.
Suresh Kumar Koushal v. Naz Foundation 2013 2-judge Reversed the Delhi High Court's 2009 decriminalisation of Sec. 377 IPC, holding the legislature — not the courts — should decide the question; itself expressly overruled by Navtej Singh Johar (2018).
Rojer Mathew v. South Indian Bank Ltd. 2019 5-judge Doubted the Aadhaar case's (2018) finding that the Aadhaar Act was validly passed as a Money Bill; referred the correctness of that finding to a larger bench — the question remains formally unresolved.

Notes. This section is deliberately grouped by doctrine rather than one continuous timeline — three clusters worth holding separately: the death-penalty trio (Bachan Singh → Machhi Singh → Mithu), the private-education-autonomy pair (T.M.A. Pai → Inamdar), and a miscellaneous set of institutional/liberty rulings (Aruna Shanbaug, Lily Thomas, Suresh Koushal, Rojer Mathew) that each connect back to a case elsewhere in the book (Common Cause, disqualification law, Navtej Singh Johar, and the Aadhaar case respectively).

Mnemonic. Death-penalty trio: "Bachan Mapped it, Mithu Made it discretionary again" — Bachan Singh (1980, rarest-of-rare born) → Machhi Singh (1983, categories mapped) → Mithu (1983, mandatory death sentence struck down). Education pair: "Pai Is Not Absolute" — T.M.A. Pai (2002, broad autonomy) → Inamdar (2005, State can't impose reservation on unaided private institutions, later narrowed by the 93rd Amendment).

Practice Recall. Before reading on: name the three death-penalty cases in order and, in one phrase each, what each one added.

Answer: Bachan Singh (1980) — created the "rarest of rare" doctrine. Machhi Singh (1983) — laid down concrete categories to apply it. Mithu (1983) — struck down the mandatory death sentence under Sec. 303 IPC, since sentencing discretion cannot be removed from judges entirely.


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