In which case it was held by the Supreme Court that – ‘Delay in deciding mercy petition is a sufficient ground for commuting the death sentence to life imprisonment’?

In Shatrughan Chouhan v. Union of India (2014), the Supreme Court held that excessive and unreasonable delay in deciding mercy petitions is a valid ground for commuting death sentence to life imprisonment. The Court ruled that such delay violates the prisoner's fundamental rights under Article 21 (right to life and personal liberty). This case established that delay itself becomes a mitigating circumstance, regardless of the merits of the mercy petition.