Manoj Rai & Ors. vs State Of M.P. on 3 August, 1998
In
Manoj and Ors. v. State of Madhya
Pradesh1, this Court in the context of death
reference cases, underscored that while
reformation is a foundational goal of
criminal punishment, repeatedly affirmed in
its jurisprudence, the absence of a
structured and measurable framework,
coupled with the inadequate
implementation of meaningful prison
1 (2023) 2 SCC 353.