The Supreme Court upheld the constitutional validity of hanging as a mode of executing the death penalty, holding that it does not violate Article 21 or the right to dignity.
The Court relied on the 1983 judgment in Deena v. Union of India, which had upheld hanging, and noted that Parliament retained hanging under Section 393(5) of the Bharatiya Nagarik Suraksha Sanhita (BNSS).
The Court held that constitutional protection continues for prisoners sentenced to death, even during execution, and that the long-drop method must be carried out with decency and without brutality or degradation.
The Law Commission’s 187th Report (2003) had recommended lethal injection as an alternative method, but the Court noted that such recommendations are not binding on Parliament.
The Court left the issue open for future reconsideration if new scientific or empirical evidence fundamentally changes the basis of the earlier Deena ruling.