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VOL. I · EST. 11.2025 
SatyaDheesh
सत्याधीश
India's Ground Truth Record
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Jhiram Valley Maoist attack case ‘rarest of rare': court order

GS3Economy · S&T · Environment · Security· Left-wing extremism· Prelims + Mains·

Judicial precedents on 'rarest of rare' cases and internal security: a GS3 and Ethics case study.

Why in news

A National Investigation Agency (NIA) court in Jagdalpur awarded death sentences to 10 convicts in the 2013 Jhiram Valley Maoist attack, classifying the crime as 'rarest of rare'.

Background

The 2013 Jhiram Valley attack resulted in the deaths of 27 people, including senior leaders Vidya Charan Shukla, Nand Kumar Patel, and Mahendra Karma. The NIA court cited the Machhi Singh (1983) and Mohd. Ajmal Mohammad Amir Kasab (2012) judgments to justify the maximum penalty.

Facts for Prelims

  • FactThe Jhiram Valley Maoist attack occurred in 2013 and resulted in 27 fatalities
  • Fact10 convicts were awarded death sentences in the Jhiram Valley case

Prelims practice question

With reference to the Jhiram Valley Maoist attack case, consider the following statements:

  1. The NIA court awarded death sentences to 10 convicts for the attack.
  2. The court classified the crime as 'common' rather than 'rarest of rare'.
  3. The attack occurred in 2013 and resulted in the deaths of 27 people.

Which of the statements given above is/are correct?

  1. (a)1 only
  2. (b)2 only
  3. (c)1 and 3 only
  4. (d)2 and 3 only
Show answer

Answer: (c) 1 and 3 only — Statements 1 and 3 are correct. Statement 2 is incorrect: The court classified the crime as 'rarest of rare'.

For Mains

Q. Discuss the judicial framework for determining the 'rarest of rare' doctrine in cases involving internal security threats and insurgent violence in India.

Dimensions to cover in your answer

  • Judicial precedent: Application of Machhi Singh and Kasab judgments to non-terrorist insurgent violence
  • Security-Judiciary nexus: Balancing the need for swift punitive measures against constitutional protections for convicts

Keywords: rarest of rare · internal security · judicial precedent · NIA · insurgency

Full chronology for revision →Read the full news →Report a mistake in this noteSource: The Hindu ↗Also: GS2 · Judiciary & landmark judgments

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