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In another case reported in Surendra Pal Shivbalakpal Vs. State of Gujarat, (2005) 3 SCC 127, involving rape and murder of a girl, the sentence of death was commuted to life imprisonment as the convict was found to be a migrant labour living in impecunious condition and also had no criminal antecedents.

In Bantu Vs. State of M.P., (2001) 9 SCC 615, the death sentence was commuted to life imprisonment as the convict was a young offender aged about 22 years and had no criminal records although the case involved a heinous rape and murder of a six year old child.