Report No. 262
(iii) Method of Execution
2.4.19 In 1983, the Supreme Court in Deena v. Union of India ('Deena'), (1983) 4 SCC 645, rejecting a constitutional challenge to execution by hanging, held that while a prisoner cannot be subjected to barbarity, humiliation, torture or degradation before the execution of the sentence, hanging did not involve these either directly or indirectly. In Deena, too, there was an attempt to revisit the constitutionality of the death sentence, but the court did not reopen the question.
2.4.20 In a later decision of Parmanand Katara v. Union of India, (1995) 3 SCC 248, the Court accepted that allowing the body to remain hanging beyond the point of deat.- the Punjab Jail Manual instructing that the body be kept hanging for half an hour after deat.- was a violation of the dignity of the person and hence unconstitutional.