MADHU MEHTA vs UNION OF INDIA

The Supreme Court held that undue delay in the execution of a death sentence can entitle a condemned person to seek commutation under Article 32 of the Constitution. The Court emphasized that while it cannot re-open the conclusions of the judicial process that confirmed the death sentence, it is obliged to consider the inordinate delay and its circumstances. The Court found that the prolonged pendency of mercy petitions without justifiable grounds constituted a violation of the right to life and liberty under Article 21, leading to the alteration of Gyasi Ram's death sentence to imprisonment for life.