BISHNU DEO SHAW @ BISHNU DAYAL vs STATE OF WEST BENGAL

The Supreme Court held that the imposition of the death penalty under Section 302 IPC requires 'special reasons' as per Section 354(3) of the Criminal Procedure Code, 1973. The Court found that the Sessions Judge failed to consider the motive behind the murder, and the High Court's reasoning for denying mercy was deemed retributive rather than justifiable. Consequently, the Court allowed the appeal regarding the sentence, emphasizing that mere adjectives like 'cruel and brutal' do not constitute special reasons for capital punishment.