Shatrughan Chauhan and Anr vs. Union of India, 2014

• The case involved multiple death row convicts whose mercy petitions had been rejected by the President of India after significant delays.​
• The petitioners approached the Supreme Court under Article 32 of the Constitution, seeking commutation of their death sentences to life imprisonment, arguing that the prolonged delay in the disposal of their mercy petitions violated their fundamental rights under Article 21 (Right to Life and Personal Liberty).
• Several writ petitions were filed under article 32 of the Indian Constitution in the Supreme Court of India either by the death-row convicts or by their relatives or by People’s Union for Democratic Rights and other like-minded public-spirited bodies. After the death-row convicts were awarded capital punishment by the Supreme Court of India, a mercy petition was filed before the Governor or the President.
• The petitioners have alleged unreasonable delay in rejecting the mercy petitions. Some of the petitioners have further stated that the death-row convicts were suffering from mental illness. Solitary confinement, judgments declared per incuriam and procedural lapses were other grounds for filing the writ petition.

Thus, the petitioners have prayed that the death sentence rendered to the convicts be commuted to life imprisonment after the mercy petition has been rejected by the President and the Governor. The petitioners prayed that the rejection of mercy petitions by the President and the Governor in the present case be declared as ultra vires. 

It was further prayed that a set of guidelines be formed by the Supreme Court of India when a mercy petition is to be considered and the rights of death row convicts are duly protected by the Supreme Court. 

1. Whether the delay in execution would amount to a violation of the right to life under Art 21.
2. Whether an undue delay in the disposal of mercy petitions can be a ground for commutation of the death sentence to life imprisonment.​
3. Whether the mental health of a death row convict should be considered while deciding on the execution of the death sentence.
4. Whether solitary confinement of death row convicts prior to the rejection of their mercy petitions is constitutionally permissible.​

The Supreme Court held that:​

• Delay in Mercy Petition Disposal: An undue and unexplained delay in the disposal of mercy petitions is a valid ground for commutation of the death sentence to life imprisonment. The Court emphasized that such delays violate the fundamental rights of the convicts under Article 21. ​
• Mental Health Considerations: The mental health of the convict is a crucial factor. If a death row convict is found to be suffering from mental illness or insanity, executing the death sentence would be unconstitutional. ​
• Solitary Confinement: The practice of keeping death row convicts in solitary confinement before the rejection of their mercy petitions is unconstitutional. Solitary confinement should only be imposed as a punishment under specific circumstances and not as a routine practice. 

The court additionally gave rules for viable overseeing of the technique of recording kindness petitions and for the reason for the passing convicts. They are as per the following:

• The singular control preceding the dismissal of the kindness request by the president is illegal and ought not be embraced.
• Much after dismissal of the benevolence appeal by the president, the convict can move toward writ court for recompense of capital punishment or challenge the dismissal of the kindness request and legitimate guide ought to be given to the convict at all stages.
• At this point, when a kindness request is gotten or imparted by the state government after the dismissal by the Governor, fundamental materials, for example, police records, judgment of the preliminary court, the HC and the SC and all other associated reports ought to be called without a moment’s delay fixing a period limit for the experts for sending the equivalent to the Ministry of Home Affairs.
• The dismissal of mercy petition by governor or president ought to forthwith be imparted to the convict and his family recorded as a hard copy. The passing convicts are qualified as a privilege for get a duplicate of the dismissal of the leniency request by the president and governor.
• It is important that the actual base time of 14 days be specified between the correspondence of the dismissal of the mercy petition and the booked date of execution. There ought to be standard emotional wellness assessment of all death row convicts and fitting clinical consideration ought to be given to those out of luck.

The duplicates of important archives ought to be outfitted to the detainee inside seven days by the jail specialists to help with making benevolence appeal and requesting of the courts. The prison specialists ought to encourage and permit a last gathering between the detainee and his loved ones before his execution. The necessary post-mortem to be led on death convicts after the execution.

At last, the court held that without legitimate, conceivable and adequate explanations behind the deferral, the postponement of twelve years in considering the kindness request is a pertinent ground for the compensation of capital punishment into life detainment. Appropriately, both the demise convicts Suresh and Ram Ji have presented out a defense for compensation of their capital punishment into life detainment.

• This judgment reinforced the humanitarian approach of the Indian judiciary towards death row convicts, emphasizing the protection of their fundamental rights.
  
  
• The Court recognized that prolonged delays in the execution of death sentences cause immense mental agony and violate the right to life and dignity.
  
  
• By addressing the issues of mental health and solitary confinement, the judgment set significant precedents for the humane treatment of prisoners. ​