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Indian Case Summary

Kehar Singh & Ors vs State (Delhi Admn.) on 3 August, 1988 – Case Summary

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In the case of Kehar Singh & Ors vs State (Delhi Admn.) on 3 August, 1988, the Supreme Court of India was confronted with a significant and high-profile case involving the assassination of the then Prime Minister, Smt. Indira Gandhi.

Facts of the Case

The case arose from the events of October 31, 1984, when Smt. Indira Gandhi was assassinated by Beant Singh and Satwant Singh, who were part of her security detail. The assassination was allegedly a result of a conspiracy hatched by the two security personnel and Kehar Singh, an Assistant in the Directorate General of Supply and Disposal, New Delhi. The conspiracy was allegedly motivated by resentment against Smt. Gandhi for the damage caused to the Akal Takht in the Golden Temple, Amritsar during the “Operation Blue Star” carried out by the Indian Army in June 1984.

On the day of the assassination, Beant Singh and Satwant Singh manipulated their duties to be present at the TMC Gate, through which Smt. Gandhi was scheduled to pass. As she approached the gate, Beant Singh fired five rounds and Satwant Singh fired 25 shots at her, resulting in her death.


The primary issues in the case revolved around the validity of the trial, the admissibility of certain evidence, and the interpretation of various sections of the Indian Penal Code, the Criminal Procedure Code, and the Indian Evidence Act.

The defense argued that the trial was not fair and open as it was held in Tihar Jail, which they claimed violated the constitutional guarantees of a fair trial. They also contested the High Court’s power to direct the trial of a case at a place other than the normal seat of the Sessions Court. Furthermore, they challenged the admissibility of the confession of Satwant Singh, which was not recorded in the manner prescribed by the Criminal Procedure Code.

Court’s Observations

The Court observed that the trial being held in Tihar Jail did not violate the constitutional right to a fair trial. It noted that the premises where the trial was held was not the part of the jail where prisoners were kept, but was the office block where there was an approach, and people were permitted to reach. The Court also held that the High Court did have the power to specify the place of hearing for individual cases.

Regarding the admissibility of Satwant Singh’s confession, the Court did not provide a clear observation in the summary provided. However, it is likely that the Court considered the validity of the confession in light of the relevant laws and the circumstances of its recording.

The Court upheld the conviction and the sentence of death on all the accused. The High Court also confirmed the other sentence on Satwant Singh. The case is significant as it involved the assassination of a sitting Prime Minister and raised important questions about the conduct of trials and the interpretation of various legal provisions.