The Supreme Court has said in one of its decisions that the criminal history of the convict in itself cannot be the sole basis for awarding death sentence. Along with this, the court has commuted the death sentence of convicted Madan to life imprisonment. However, the apex court has said in the judgment that the plea for premature release of convict Madan will not be considered before serving the actual imprisonment of 20 years.

This case of Muzaffarnagar, Uttar Pradesh was of murder of six people in which the sessions court had sentenced three culprits, Ishwar, Madan and Sudesh Pal. The sessions court had sentenced Ishwar to life imprisonment and given death penalty to Madan and Sudesh Pal, while the Allahabad High Court had commuted the death sentence of Sudesh Pal to life imprisonment, but kept the death sentence of Madan intact.

Both Madan and Sudesh Pal had filed appeals against their sentences in the Supreme Court. Justices BR Gavai, B.V. Nagarathna, and Prashant Kumar Mishra delivered their verdict on November 9. The Supreme Court partially granted Madan's appeal, reducing his death sentence to life imprisonment, while dismissing Sudesh Pal's appeal and upholding his life sentence. It is worth noting that the court found both of them guilty.

The Supreme Court, while commuting Madan's death sentence to life imprisonment, has said that the High Court gave death sentence to Madan after considering the same evidence, while partially accepting the appeal of convict Sudesh Pal, he commuted the death sentence to life imprisonment. Had converted.

The Supreme Court said that seeing the decision of the High Court shows that the High Court has made a difference in the case of Sudesh Pal and Madan on only one basis and that is that Madan has already been sentenced to life imprisonment in another case. 

The Supreme Court said that it has already said in the earlier case of Rajendra Pralhadrao Wasnik that while giving death sentence to someone, his previous conduct i.e. previous criminal history is not an issue for consideration. The High Court said that in the present case, based on the statements of the eyewitnesses, the role of all the culprits was equal. In view of these things, he believes that the decision of the High Court to confirm the death sentence of Madan and to give life imprisonment to Sudesh Pal is not justified.

The Supreme Court said that it would be in the interest of justice to commute the death sentence awarded to Madan to life imprisonment and give him actual imprisonment for 20 years. Saying this, the court partially accepted Madan's appeal and commuted his death sentence to life imprisonment with 20 years of fixed imprisonment.

The Supreme Court, while considering death penalty in this case, has taken into consideration many other aspects and had also sought a report from the probation officer on Madan's conduct in jail. This case of murder of six people took place on October 14, 2003, in which the firing allegedly took place due to political and family rivalry.