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In Panchhi v. State of U.P., [(1998) 7 SCC 177], this Court also elucidates on "when the alternative option is foreclosed" benchmark in the following terms:
16. When the Constitution Bench of this Court, by a majority, upheld the constitutional validity of death sentence in Bachan Singh v. State of Punjab this Court took particular care to say that death sentence shall not normally be awarded for the offence of murder and that it must be confined to the rarest of rare cases when the alternative option is foreclosed. In other words, the Constitution Bench did not find death sentence valid in all cases except in the aforesaid freaks wherein the lesser sentence would be, by any account, wholly inadequate. In Machhi Singh v. State of Punjab a three-Judge Bench of this Court while following the ratio in Bachan Singh case laid down certain guidelines among which the following is relevant in the present case: (SCC p. 489, para 38) "(iv) A balance-sheet of aggravating and mitigating circumstances has to be drawn up and in doing so the mitigating circumstances have to be accorded full weightage and a just balance has to be struck between the aggravating and the mitigating circumstances before the option is exercised."
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Bachan Singh (supra) elaborated on "well recognized principles" in the following terms:

"197. In Jagmohan, this Court had held that this sentencing discretion is to be exercised judicially on well recognised principles, after balancing all the aggravating and mitigating circumstances of the crime. By "well recognised principles" the court obviously meant the principles crystallised by judicial decisions illustrating as to what were regarded as aggravating or mitigating circumstances in those cases. The legislative changes since Jagmohan -- as we have discussed already -- do not have the effect of abrogating or nullifying those principles. The only effect is that the application of those principles is now to be guided by the paramount beacons of legislative policy discernible from Sections 354(3) and 235(2), namely: (1) The extreme penalty can be inflicted only in gravest cases of extreme culpability; (2) In making choice of the sentence, in addition to the circumstances, of the offence, due regard must be paid to the circumstances of the offender, also."

Next step would be to deal with the subjectivity involved in capital cases. The imprecision of the identification of aggravating and mitigating circumstances has to be minimized. It is to be noted that the mandate of equality clause applies to the sentencing process rather than the outcome. The comparative review must be undertaken not to channel the sentencing discretion available to the courts but to bring in consistency in identification of various relevant circumstances.

The aggravating and mitigating circumstances have to be separately identified under a rigorous measure. Bachan Singh (supra), when mandates principled precedent based sentencing, compels careful scrutiny of mitigating circumstances and aggravating circumstances and then factoring in a process by which aggravating and mitigating circumstances appearing from the pool of comparable cases can be compared.

However while imposing the sentence of imprisonment for life on Sanjeeb Kumar Roy (A 2) and Santosh Kumar Roy (A 3) the learned Sessions Judge noted:

"As far as the Accused Nos. 2 and 3 are concerned, it is evident from the proven facts that they accepted the plan of Accused No. 1 only for monetary gain. The plan was possessed by accused No. 1 only. The Accused Nos. 2 and 3 as well as the approver Kumar Gaurav were motivated by accused No.1 Santosh Kumar Bariyar and therefore, they all hatched [a] criminal conspiracy. Hence it cannot be disputed that the Accused Nos. 2 and 3 participated in the commission of [the] crime at the behest of Accused No. 1 Santosh Kumar Bariyar, which can be considered as a mitigating circumstance. Considering this mitigating circumstance and ages of Accused Nos. 2 and 3, in my view, it will be just and proper to give them an opportunity to reform and rehabilitate by imposing minimum sentence of life imprisonment."