टी.वी. वतीश्वरन बनाम तमिलनाडु राज्य
| Citation | AIR 1983 SC 361 |
| Court | Supreme Court of India |
| Date | 16 February 1983 |
| Year | 1983 |
| Bench | O. Chinnappa Reddy, R.B. Misra JJ. |
| Acts/Articles | Article 21, Article 32 |
| Category | Constitutional Law, Criminal Law |
Key Principle Established
Delay exceeding two years in execution of death sentence entitles the prisoner to invoke Article 21 for commutation to life imprisonment.
A death row prisoner had been condemned over 8 years ago and kept in solitary confinement. He argued that it was no longer lawful to execute him due to the prolonged delay.
The Court held that delay exceeding two years in execution of death sentence is sufficient to invoke Article 21 for commutation to life imprisonment. Prolonged delay on death row, with its psychological agony, constitutes cruel and inhuman punishment.
Though the rigid two-year rule was later modified by the Constitution Bench in Sher Singh v. State of Punjab (1983) and Triveniben (1988), the principle that unreasonable delay is a ground for commutation remains established law, as reaffirmed in Shatrughan Chauhan (2014).
(1982) 1 SCC 618
Equal pay for equal work is a constitutional goal derivable from Articles 14, 16, and 39(d) read together.
Read Analysis(2020) 9 SCC 1
Daughters have equal coparcenary rights by birth under the Hindu Succession (Amendment) Act, 2005 — irrespective of whether the father…
Read Analysis(1984) 1 SCC 131
An institution receiving government grants is "State" under Article 12. Employees of such bodies are entitled to Article 14 and…
Read AnalysisThis judgment summary is for educational and research purposes. While care has been taken to accurately represent the ratio and findings, for authoritative reference always consult the original judgment text from official sources (SCC Online, AIR, Manupatra, or court websites).
22+ years of practice before Punjab & Haryana High Court and Supreme Court of India.