Bachan Singh Etc. Etc vs State Of Punjab Etc. Etc on 16 August, 1982
In Panchhi v. State of U.P., it has been observed that
the brutality of the manner in which the murder was
perpetrated may not be the sole ground for judging
whether the case is one of the 'rarest of rate cases',
as indicated in Bachan Singh v. State of Punjab and
that every murder being per se brutal, the
distinguishing factors should really be the
mitigating or aggravating features surrounding the
murder. The intensity of bitterness, which prevailed,
and the escalation of simmering thoughts into a
thirst for revenge or retaliation were held to be also
a relevant factor."