नवनीत कौर बनाम दिल्ली राज्य (भुल्लर मामला)
| Citation | Curative Petition (Crl.) No. 88 of 2013 |
| Court | Supreme Court of India |
| Date | 31 March 2014 |
| Year | 2014 |
| Bench | P. Sathasivam CJI, R.M. Lodha, H.L. Dattu, S.J. Mukhopadhaya JJ. |
| Acts/Articles | Article 21, Article 72, TADA |
| Category | Constitutional Law, Criminal Law |
Key Principle Established
Inordinate delay in disposal of mercy petition and mental illness are supervening circumstances for commutation of death sentence, applicable to all cases including TADA.
Devender Pal Singh Bhullar was sentenced to death under TADA for a bomb blast. His mercy petition under Article 72 remained pending for 8 years. He also developed severe mental illness during incarceration. The earlier judgment had held that TADA convicts could not claim commutation on grounds of delay.
Following Shatrughan Chauhan v. UOI (2014), the Court held that the distinction between IPC and TADA offences for considering supervening circumstances was per incuriam. Inordinate delay in disposal of mercy petition and mental illness are valid grounds for commutation regardless of the nature of the offence.
This judgment established that supervening circumstances for commutation apply universally — no category of offence can be excluded as a class. It humanized death penalty jurisprudence by recognizing mental illness as a ground for commutation.
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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.