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VOL. I · EST. 11.2025 
SatyaDheesh
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Jhiram Valley Maoist attack case ‘rarest of rare': court order

GS3Economy · S&T · Environment · Security· Left-wing extremism· Prelims + Mains·

Judicial precedents on 'rarest of rare' cases and internal security: a GS3 and Ethics case study.

Why in news

A National Investigation Agency (NIA) court in Jagdalpur awarded death sentences to 10 convicts for the 2013 Jhiram Valley Maoist attack, classifying the crime as 'rarest of rare'.

Background

The 2013 Jhiram Valley attack resulted in the deaths of 27 people, including senior leaders Vidya Charan Shukla, Nand Kumar Patel, and Mahendra Karma. The NIA court cited the Machhi Singh (1983) and Mohd. Ajmal Mohammad Amir Kasab (2012) judgments to justify the maximum penalty.

Facts for Prelims

  • FactThe Jhiram Valley Maoist attack occurred in 2013 and resulted in 27 fatalities
  • Fact10 convicts were awarded death sentences in the Jhiram Valley case

Prelims practice question

With reference to the Jhiram Valley Maoist attack case, consider the following statements:

  1. The NIA court awarded death sentences to 10 convicts for the attack.
  2. The court classified the crime as 'common' rather than 'rarest of rare'.
  3. The attack occurred in 2013 and resulted in the deaths of 27 people.

Which of the statements given above is/are correct?

  1. (a)1 only
  2. (b)2 only
  3. (c)1 and 3 only
  4. (d)2 and 3 only
Show answer

Answer: (c) 1 and 3 only — Statements 1 and 3 are correct. Statement 2 is incorrect: The court classified the crime as 'rarest of rare'.

For Mains

Q. Discuss the judicial criteria for determining 'rarest of rare' cases in the context of internal security threats and terrorism in India.

Dimensions to cover in your answer

  • Judicial precedent: Application of Machhi Singh and Kasab judgments to determine severity of crime
  • Security-Legal nexus: Balancing the need for punitive deterrence against the constitutional right to life
  • Institutional role: NIA's mandate in prosecuting high-impact insurgency-related crimes

Keywords: rarest of rare · internal security · judicial precedent · NIA · deterrence · insurgency

Full chronology for revision →Read the full news →Report a mistake in this noteSource: The Hindu ↗Also: GS2 · Judiciary & landmark judgments

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