Section 22 of BNSS 2023: Complete Guide to Sentencing Powers of High Courts and Sessions Judges
Introduction: Why Section 22 BNSS Matters in India's N
Section 22 of BNSS 2023: Complete Guide to Sentencing Powers of High Courts and Sessions Judges
Introduction: Why Section 22 BNSS Matters in India's New Criminal Justice System
Imagine walking into a courtroom where the judge holds the power to decide whether someone spends their life in prison, walks free, or in the most extreme cases, faces the gallows. Section 22 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 is the provision that draws the lines of this immense power. It tells us who can pass what sentence in India's criminal courts, and more importantly, it establishes the critical safeguards that prevent arbitrary use of the death penalty.
When India woke up to a new criminal justice era on July 1, 2024, three new laws replaced the colonial-era codes that had governed us for over a century. The Indian Penal Code gave way to the Bharatiya Nyaya Sanhita (BNS), the Code of Criminal Procedure was replaced by the Bharatiya Nagarik Suraksha Sanhita (BNSS), and the Indian Evidence Act became the Bharatiya Sakshya Adhiniyam (BSA). Among these transformative changes, Section 22 of BNSS stands out as a provision that combines continuity with meaningful reform.
This section corresponds to Section 28 of the old CrPC, 1973, but it carries one significant deletion that has reshaped the judicial hierarchy — the abolition of the Assistant Sessions Judge. In this comprehensive guide, we will explore every word of Section 22, understand its practical implications, examine recent case laws from 2025 and 2026, and see how this provision interacts with the death penalty confirmation process under Sections 407-412 of BNSS.
Whether you are a law student preparing for judiciary exams, a practicing advocate, or simply someone interested in understanding how India's criminal courts function, this article will walk you through everything you need to know about Section 22 BNSS in plain, simple language.
The Exact Text of Section 22 BNSS: Reading the Law As It Stands
Before we dive into interpretations and case laws, let us look at the exact wording of Section 22 of the Bharatiya Nagarik Suraksha Sanhita, 2023. This is the foundation upon which everything else rests:
"22. Sentences which High Courts and Sessions Judges may pass.(1) A High Court may pass any sentence authorised by law.(2) A Sessions Judge or Additional Sessions Judge may pass any sentence authorised by law; but any sentence of death passed by any such Judge shall be subject to confirmation by the High Court."
That's it. Two subsections, barely three lines, yet they carry the weight of life and death decisions in Indian courts. Let us break this down piece by piece.
Subsection (1): The Unlimited Power of the High Court
"A High Court may pass any sentence authorised by law."
These nine words grant the High Court of each state the most extensive sentencing power in the criminal justice system. When we say "any sentence authorised by law," we mean:
- Death penalty — The High Court can directly sentence a person to death without needing confirmation from any other court
- Life imprisonment — Including life imprisonment without remission for the remainder of the convict's natural life
- Imprisonment for fixed terms — Whether it is 10 years, 20 years, or any duration prescribed by the Bharatiya Nyaya Sanhita or special laws
- Fines — Of any amount that the law permits
- Community service — As introduced in the new sentencing framework
- Any combination of the above sentences
The phrase "authorised by law" is crucial here. It means the High Court cannot invent punishments. The punishment must be prescribed either in the Bharatiya Nyaya Sanhita, 2023 (which replaced the IPC) or in any special law such as the Prevention of Corruption Act, the Narcotic Drugs and Psychotropic Substances Act (NDPS), the Prevention of Money Laundering Act (PMLA), or any other legislation that creates criminal offences.
Why This Unlimited Power Makes Sense
The High Court is the apex judicial authority within a state. It is a constitutional court established under Article 214 of the Constitution of India. Its judges are among the most experienced in the judicial hierarchy, having typically served as district judges or advocates with substantial practice before elevation. When the legislature entrusted the High Court with unlimited sentencing power, it recognized that:
- The High Court has the maturity and experience to handle the gravest criminal cases
- It serves as the court of appeal for death sentences passed by Sessions Courts, requiring it to have at least equal sentencing power
- Its decisions are subject to further appeal to the Supreme Court, providing a check on its discretion
In practical terms, when a case reaches the High Court through appeal, revision, or reference, the High Court can not only confirm or set aside the lower court's decision but also modify the sentence in any manner permitted by law. If the Sessions Court awarded 10 years imprisonment, the High Court can enhance it to life imprisonment. If the lower court imposed life imprisonment, the High Court can reduce it to a fixed term. And in the rarest of rare cases, if the High Court finds that the Sessions Court was too lenient, it can even enhance a sentence to death penalty — a power explicitly recognized in the criminal procedure framework.
Subsection (2): The Power and Limitation of Sessions Judges
"A Sessions Judge or Additional Sessions Judge may pass any sentence authorised by law; but any sentence of death passed by any such Judge shall be subject to confirmation by the High Court."
This subsection does two things simultaneously — it empowers and it restricts.
The Empowerment Part
A Sessions Judge or Additional Sessions Judge can pass any sentence authorised by law, just like the High Court. This includes:
- Life imprisonment for the remainder of the convict's natural life
- Imprisonment for any term
- Fines of any amount permitted by law
- Death penalty (but with the crucial confirmation requirement)
Sessions Courts are the principal trial courts for serious criminal offences in India. When someone is charged with murder, rape, dacoity, or other heinous crimes, the case typically goes to the Court of Session. The Sessions Judge is the judicial officer who presides over these trials, examines witnesses, evaluates evidence, and delivers judgments. The Additional Sessions Judge is appointed by the High Court to assist the Sessions Judge and has equivalent powers.
The fact that Sessions Judges can pass any sentence reflects the seriousness of the cases they handle. Unlike Magistrates who deal with relatively minor offences, Sessions Courts are designed to handle crimes that can attract the most severe punishments under Indian law.
The Restriction: Death Penalty Confirmation
The words "but any sentence of death passed by any such Judge shall be subject to confirmation by the High Court" create one of the most important procedural safeguards in India's criminal justice system. This is not merely an administrative formality — it is a mandatory, substantive review that must occur before any death sentence can be executed.
Here is how this works in practice:
- The Sessions Judge conducts a full trial, examines all evidence, hears arguments from both prosecution and defense, and if convinced that the case falls in the "rarest of rare" category, awards the death penalty
- The judgment cannot be executed immediately
- The entire proceedings must be submitted to the High Court under Section 407 of BNSS
- The High Court must independently examine the evidence, the legal reasoning, and the sentencing decision
- Only after the High Court confirms the death sentence can it become executable
- If the High Court refuses confirmation, the sentence is effectively set aside or modified
This confirmation requirement exists because death is irreversible. Once executed, no court can bring back the condemned person. The legislature wisely decided that two judicial minds — the Sessions Judge and the High Court — must agree before the state can take a citizen's life.
The Major Change: Abolition of Assistant Sessions Judge
If you compare Section 22 of BNSS with Section 28 of the old CrPC, you will notice one significant deletion. The old CrPC had a subsection (3) that read:
"An Assistant Sessions Judge may pass any sentence authorised by law except a sentence of death or of imprisonment for life or of imprisonment for a term exceeding ten years."
This provision has been completely removed from the BNSS. The post of Assistant Sessions Judge has been abolished under the new law.
What This Means Practically
Under the old system, India's criminal courts had a three-tier Sessions Court structure:
- Sessions Judge — Full powers including death penalty (with confirmation)
- Additional Sessions Judge — Full powers including death penalty (with confirmation)
- Assistant Sessions Judge — Limited powers; could not award death, life imprisonment, or imprisonment exceeding 10 years
The BNSS has streamlined this into two tiers:
- Sessions Judge — Full powers
- Additional Sessions Judge — Full powers
The Assistant Sessions Judge position has been eliminated entirely.
Why Was This Change Made?
The abolition of the Assistant Sessions Judge reflects a deliberate policy choice to ensure that the most serious criminal cases are handled only by the most experienced judicial officers. Consider these points:
- Consistency in quality: Cases involving grave offences like murder, rape, and terrorism require judicial officers with substantial experience. The Assistant Sessions Judge position often served as a stepping stone for relatively junior judges, and limiting their sentencing power created an artificial barrier
- Elimination of jurisdictional confusion: Under the old system, cases had to be carefully allocated based on the potential sentence. If mid-trial it appeared that the offence might attract more than 10 years, the case had to be transferred. This caused delays and procedural complications
- Uniformity across states: Different states had varying numbers of Assistant Sessions Judges, creating uneven distribution of judicial workload. The streamlined system ensures uniformity
- Simplified hierarchy: With only two tiers in the Sessions Court, the administrative structure becomes cleaner and more efficient
Transition of Pending Cases
A practical question arises: What happened to cases that were pending before Assistant Sessions Judges when the BNSS came into force on July 1, 2024? The general principle is that transitional provisions apply, and such cases are typically transferred to Additional Sessions Judges to ensure continuity without loss of judicial time. The High Courts across states issued appropriate notifications and orders to facilitate this transition smoothly.
The Death Penalty Confirmation Process: Sections 407-412 BNSS
Section 22(2) of BNSS tells us that death sentences passed by Sessions Judges require High Court confirmation. But how exactly does this confirmation process work? The detailed procedure is laid out in Chapter XXX of BNSS, comprising Sections 407 to 412. Understanding these sections is essential to fully grasp the practical operation of Section 22.
Section 407: Submission of Death Sentence for Confirmation
When a Court of Session passes a death sentence, the proceedings shall forthwith be submitted to the High Court. The sentence shall not be executed unless it is confirmed by the High Court. The court passing the sentence must commit the convicted person to jail custody under a warrant.
This "jail custody" is important to understand — it is not punishment but safe keeping. The convict remains in custody during the confirmation process, but this detention is protective rather than punitive. The Supreme Court has clarified in State of Punjab v. Kala Ram @ Kala Singh that the jailor acts as a custodian, not as an enforcer of punishment.
Section 408: Power to Direct Further Inquiry or Additional Evidence
The High Court is not bound to simply rubber-stamp the Sessions Court's decision. If the High Court feels that certain aspects need further investigation — perhaps some evidence was not properly examined, or new facts have come to light — it can:
- Make such inquiry itself, or
- Direct the Sessions Court to make the inquiry and submit a certified report
The accused need not be physically present during these additional proceedings unless the High Court specifically directs otherwise.
Section 409: Powers of the High Court on Confirmation
This section gives the High Court broad powers when reviewing a death sentence:
- Confirm the sentence if satisfied with the trial court's decision
- Pass any other sentence warranted by law — this includes reducing death penalty to life imprisonment, or modifying the sentence in any other permissible manner
- Annul the conviction and either convict the accused of a lesser offence, order a new trial, or acquit the accused entirely
However, the High Court cannot confirm the death sentence until:
- The period allowed for filing an appeal has expired, OR
- If an appeal is filed, until such appeal is disposed of
This ensures that the accused has a full opportunity to challenge the conviction and sentence before the confirmation becomes final.
Section 410: Confirmation by Multiple Judges
If the High Court consists of two or more judges, the confirmation of a death sentence must be made, passed, and signed by at least two judges. This means a single judge cannot confirm a death sentence — there must be concurrence by at least two judicial minds.
Section 411: Procedure in Case of Equal Division of Opinion
What happens if two judges of the High Court disagree — one wants to confirm the death sentence and the other wants to commute it? In such cases, Section 433 of BNSS applies. The case is referred to a third judge who hears the matter and delivers an opinion. The majority view prevails. If the third judge also creates a situation where no clear majority emerges, the matter can be referred to a larger bench.
Section 412: Communication of the Order
Once the High Court passes its order — whether confirming, modifying, or annulling the sentence — a certified copy must be sent to the Sessions Court without delay. The BNSS modernizes this by allowing digital or electronic communication of the order, though it must bear the seal and signature of the High Court officer.
Recent Case Laws on Section 22 BNSS and Death Penalty Confirmation (2025-2026)
The real test of any law lies in how courts interpret and apply it. Since the BNSS came into force on July 1, 2024, several important cases have emerged that illuminate the working of Section 22 and the death penalty confirmation process. Let us examine the most significant ones.
1. Atul Nihale v. State of Madhya Pradesh (Madhya Pradesh High Court, January 2026)
This case represents one of the first major death penalty confirmations under the BNSS regime and provides crucial insights into how Section 22 operates in practice.
The Facts: Atul Nihale was convicted by a Special Judge (POCSO) for the rape and murder of a five-year-old girl child. The trial court found the crime to be committed in a "barbarous manner" and awarded triple death sentence — one each under Section 103 of BNS (murder), Section 65(2) of BNS read with Section 5(m)/6 of POCSO Act, and related provisions.
The High Court's Role: The Special Judge submitted a reference under Section 407 of BNSS for confirmation of the death sentence, as mandated by Section 22(2). The Madhya Pradesh High Court, with Justice Vivek Agarwal presiding, independently examined the entire evidence.
The Confirmation: The High Court affirmed the conviction in its judgment dated January 22, 2026, holding that the evidence formed a complete and unbroken chain of circumstances establishing the accused's guilt with absolute certitude. The court noted the brutal nature of the crime, the tender age of the victim, and the robust evidence against the accused.
The Sentence Consideration: In the reference proceedings, the State argued that the case fell squarely within the "rarest of rare" category given the barbarous manner of the crime and the age of the deceased. The defense pleaded mitigating circumstances — that the accused was a labour-class person, married with wife and children, and that capital punishment would ruin his family's life.
The Outcome: The High Court maintained the death sentence, finding that the aggravating circumstances overwhelmingly outweighed any mitigating factors. This case demonstrates that under Section 22(2), the High Court acts as a rigorous filter before any death sentence can attain finality.
Significance: This was one of the earliest confirmations of a triple death sentence under the BNSS, establishing that the procedural safeguards of Sections 407-412 are being strictly enforced even as courts continue to award the ultimate punishment in the most heinous cases.
2. Vasanta Sampat Dupare v. Union of India (Supreme Court, August 2025)
While this case did not directly arise under Section 22, it has profound implications for how death sentences are confirmed and reviewed under the BNSS framework. This judgment, delivered by a three-judge bench of Justice Vikram Nath, Justice Sanjay Karol, and Justice Sandeep Mehta, is a watershed moment in Indian capital sentencing jurisprudence.
The Background: Vasanta Sampat Dupare was convicted in 2008 for the rape and murder of a four-year-old girl. His death sentence was confirmed by the Bombay High Court, affirmed by the Supreme Court in November 2014, and his review petition was dismissed in May 2017. His mercy petitions to the Governor and President were rejected in 2022 and 2023 respectively.
The New Development: In 2022, the Supreme Court in Manoj v. State of Madhya Pradesh laid down mandatory guidelines for capital sentencing. These guidelines require trial courts to obtain mitigation reports covering:
- Psychiatric and psychological evaluation
- Socio-economic and family history
- Educational attainments
- Prior conduct and criminal antecedents
- Contemporaneous jail behavior reports
Dupare filed a writ petition under Article 32 arguing that his death sentence was affirmed without these safeguards, violating his fundamental rights under Articles 14 and 21 of the Constitution.
The Supreme Court's Ruling: The Court held that Article 32 empowers the Supreme Court to revisit even final death sentences where there has been a grave breach of procedural safeguards that undermines the accused's right to life. The Court clarified that:
- The finding of guilt remains untouched — only the sentence is revisited
- The Manoj guidelines apply retrospectively to all death row prisoners
- Article 32 is the "heart and soul" of the Constitution and cannot be rendered ineffective by procedural finality
- However, such reopening is limited to rare cases involving serious procedural lapses
The Outcome: The Supreme Court set aside its own 2017 order confirming the death sentence and remitted the matter for a fresh sentencing hearing in conformity with the Manoj guidelines.
Implications for Section 22: This judgment elevates the confirmation process under Section 22(2) from a mere review of guilt to a deep, individualized examination of the convict's circumstances. High Courts confirming death sentences under Sections 407-412 must now ensure that all mitigating material has been properly considered by the trial court. If the trial court failed to obtain psychological evaluations or socio-economic reports, the High Court must either remand for fresh sentencing or obtain the material itself before confirmation.
3. Karnataka Triple Death Sentence Case (Supreme Court, April 2026)
In April 2026, a three-judge bench of the Supreme Court comprising Justice Vikram Nath, Justice Sandeep Mehta, and Justice N.V. Anjaria stayed three death sentences awarded to convicts in a rape and murder case from Dakshina Kannada, Karnataka.
The Facts: The trial court had convicted three persons and sentenced them to death in October 2024 for rape and murder under the BNS and POCSO Act. The Karnataka High Court confirmed the death penalty on February 6, 2026, under the Section 22(2) confirmation process.
The Supreme Court's Intervention: The Supreme Court stayed the execution and reopened the sentencing question on two critical grounds:
- The High Court had loosely engaged with the mitigation question in a single paragraph, failing to give proper weight to the accused's individual circumstances
- The High Court had not considered an intermediate punishment — something between ordinary life imprisonment and death penalty, such as life without remission for a fixed term
The Directions: The Supreme Court ordered the Karnataka government to file:
- Probation officer's reports on each appellant
- Jail conduct reports from Shivamogga Central Jail
- Psychological evaluations by a team at Shivamogga Institute of Medical Sciences
The Court also directed Komal, Mitigation Associate at the Square Circle Clinic, to be granted confidential access to the appellants and to file a Mitigation Investigation Report within 20 weeks.
Significance for Section 22: This case demonstrates that the High Court's confirmation power under Section 22(2) is not a perfunctory exercise. The Supreme Court expects High Courts to conduct a meaningful, individualized assessment of mitigating circumstances before confirming death sentences. A cursory confirmation that fails to engage with the "rarest of rare" doctrine's balancing test can be set aside by the Supreme Court.
4. State of Haryana v. [Convict] (Punjab and Haryana High Court, January 2026)
In this significant confirmation proceeding, the Punjab and Haryana High Court refused to confirm a death sentence passed by a Sessions Judge, reinforcing the protective role of Section 22(2).
The Reasoning: The High Court found that the "Special Reasons" recorded by the Sessions Judge for awarding the death penalty were not sufficiently detailed. Under Section 393(3) of BNSS, any judgment imposing the death penalty must include special reasons explaining why such a sentence is justified. The High Court held that generic observations about the brutality of the crime were inadequate without a specific balancing of aggravating and mitigating circumstances.
The Outcome: The death sentence was not confirmed, and the matter was remanded for fresh sentencing or the sentence was modified to life imprisonment (depending on the final order).
Lesson: This case reinforces that Section 22(2) is not automatic. The High Court must apply its independent judicial mind and ensure that the trial court has complied with all procedural and substantive requirements before confirming the ultimate punishment.
Section 22 in Context: Comparison with Section 23 BNSS (Magistrates' Powers)
To fully appreciate Section 22, we must understand what it is not. While Section 22 grants unlimited sentencing power (subject to death confirmation) to High Courts and Sessions Judges, Section 23 of BNSS severely restricts the powers of Magistrates. This contrast illuminates the hierarchical structure of India's criminal courts.
Chief Judicial Magistrate (Section 23(1))
The Court of a Chief Judicial Magistrate may pass any sentence authorized by law EXCEPT:
- A sentence of death
- A sentence of imprisonment for life
- A sentence of imprisonment for a term exceeding seven years
So the maximum imprisonment a Chief Judicial Magistrate can award is seven years.
Judicial Magistrate of First Class (Section 23(2))
- Imprisonment up to three years, OR
- Fine up to ₹50,000 (increased from ₹10,000 under the old CrPC), OR
- Both imprisonment and fine, OR
- Community service
Judicial Magistrate of Second Class (Section 23(3))
- Imprisonment up to one year, OR
- Fine up to ₹10,000 (increased from ₹5,000 under the old CrPC), OR
- Both imprisonment and fine, OR
- Community service
The "Community Service" Innovation
The BNSS introduces community service as a formal sentencing option for Magistrates. The Explanation to Section 23 defines it as "the work which the Court may order a convict to perform as a form of punishment that benefits the community, for which he shall not be entitled to any remuneration." This is a new addition that did not exist in the CrPC and reflects modern penological thinking focused on reformation and restorative justice.
Why the Hierarchy Matters
This clear hierarchy ensures that:
- The most serious crimes (murder, rape, terrorism, etc.) are tried by the most experienced judges with the broadest sentencing powers
- Less serious offences are handled by Magistrates, ensuring speedy disposal of the bulk of criminal cases
- No single judge at the lower level can impose the most extreme punishments without the oversight of the High Court (in the case of death penalty)
The Constitutional Dimension: Article 21 and the Death Penalty
Section 22 of BNSS does not operate in a vacuum. It exists within a constitutional framework where Article 21 guarantees that no person shall be deprived of his life or personal liberty except according to procedure established by law. The death penalty confirmation requirement in Section 22(2) is a critical component of this "procedure established by law."
The Supreme Court has consistently held that:
- The death penalty is constitutional but must be restricted to the "rarest of rare" cases (Bachan Singh v. State of Punjab, 1980)
- The manner of execution must be humane (Deena v. Union of India, 1983)
- Undue delay in execution can be a ground for commutation (Shatrughan Chauhan v. Union of India, 2014)
- Mental illness and intellectual disability must be considered (Vasanta Sampat Dupare, 2025)
- Mitigation reports are mandatory before awarding death (Manoj v. State of M.P., 2022)
Section 22(2)'s confirmation requirement ensures that at least two levels of judicial scrutiny — the Sessions Court and the High Court — examine whether a case truly falls within the "rarest of rare" category before the ultimate punishment is imposed.
Practical Challenges and Criticisms
Despite its noble intent, the operation of Section 22 and the death penalty confirmation process faces several practical challenges:
Delay in Confirmation Proceedings
Death row prisoners often spend years waiting for High Court confirmation. While this delay is preferable to hasty execution, the uncertainty and mental agony of prolonged death row incarceration has been recognized by the Supreme Court as a potential violation of Article 21.
Inconsistent Application of Mitigation Guidelines
Studies and reports indicate that nearly 95% of death sentences awarded by trial courts in 2025 were imposed without full compliance with the Manoj guidelines. This means High Courts are frequently asked to confirm sentences that were awarded without proper psychological evaluations or socio-economic reports.
High Rate of Reversal
Data shows that High Courts confirm only about 8-10% of death sentences placed before them. While this demonstrates robust scrutiny, it also raises questions about why trial courts continue to award death sentences at such high rates (128 death sentences by Sessions Courts in 2025 alone) when the vast majority are reversed on appeal or confirmation.
The "Assistant Sessions Judge" Gap
The abolition of Assistant Sessions Judges, while simplifying the hierarchy, has practical implications for judicial workload. With only Sessions Judges and Additional Sessions Judges handling all serious cases, there is a risk of increased pendency unless more Additional Sessions Judges are appointed to fill the gap.
Conclusion: Section 22 as a Guardian of Life and Liberty
Section 22 of the BNSS, 2023 is much more than a procedural provision about who can pass what sentence. It is a constitutional safeguard that embodies the tension between state power and individual rights. By granting unlimited sentencing power to High Courts, it recognizes the need for experienced judicial oversight in the gravest criminal cases. By requiring High Court confirmation for death sentences passed by Sessions Judges, it ensures that no single judge can unilaterally decide to take a citizen's life.
The abolition of the Assistant Sessions Judge reflects a modernizing impulse — simplifying the judicial hierarchy and ensuring that only the most experienced hands touch the most serious cases. The recent case laws from 2025 and 2026 show that Indian courts are actively grappling with the profound responsibility that Section 22 places upon them.
As the BNSS continues to be interpreted and applied, Section 22 will remain at the heart of India's capital punishment jurisprudence. It reminds us that in a constitutional democracy, even the most heinous crimes must be met with procedures that honor the dignity of every individual — including the condemned. The law's majesty lies not in the severity of its punishments, but in the care with which those punishments are imposed.
Source Links and References
- Bharatiya Nagarik Suraksha Sanhita, 2023 (Full Text): https://www.indiacode.nic.in/bitstream/123456789/21544/1/the_bharatiya_nagarik_suraksha_sanhita%2C_2023.pdf
- Atul Nihale v. State of Madhya Pradesh (Madhya Pradesh High Court, 22 January 2026): https://indiankanoon.org/doc/159823083/
- Vasanta Sampat Dupare v. Union of India (Supreme Court, 25 August 2025): https://lawbeat.in/news-updates/sc-reopens-death-sentence-of-child-rape-murder-convict-vasanta-sampat-dupare-1516049
- Supreme Court Stays Three Death Sentences, Orders Full Mitigation Inquiry (April 2026): https://www.scobserver.in/journal/supreme-court-stays-three-death-sentences-orders-full-mitigation-inquiry/
- Death Penalty Under BNSS - Vidhishala Analysis: https://www.vidhishala.co.in/blog/our-blog-1/death-penalty-under-bnss-4
- Abolition of Assistant Sessions Judge - LiveLaw Analysis: https://www.livelaw.in/articles/abolition-of-assistant-session-judge-post-under-bnss-critical-analysis-280499
- Power of Courts Under BNSS - Drishti Judiciary: https://www.drishtijudiciary.com/bharatiya-nagarik-suraksha-sanhita-&-code-of-criminal-procedure/power-of-courts-under-bnss
- Section 22 BNSS - Lexibal Analysis: https://lexibal.com/bnss-section-22-sentencing-powers-death-penalty/
- Section 22 BNSS - Prashant Kanha (AOR Supreme Court): https://www.prashantkanha.com/section-22-bnss-bhartiya-nagarik-suraksha-sanhita-2023-equivalent-cr-p-c-section/
- Submission of Death Sentences for Confirmation - BNSS Chapter XXX: https://bharatiyanagariksurakshasanhita.com/submission-of-death-sentences-for-confirmation/
- Death Penalty in India - Drishti IAS: https://www.drishtiias.com/daily-updates/daily-news-analysis/death-penalty-in-india
- Supreme Court Observer - Vasanta Sampat Dupare Case Analysis: https://www.scobserver.in/supreme-court-observer-law-reports-scolr/vasanta-sampat-dupare-v-union-of-india-revisiting-sentence-article-32-violation-death-penalty/
- LiveLaw - Current Scenario on Death Penalty Under BNSS: https://www.livelaw.in/articles/death-penalty-under-bharatiya-nagarik-suraksha-sanhita-280919
- Bharatiya Nagarik Suraksha Sanhita, 2023 - PRS India: https://prsindia.org/billtrack/the-bharatiya-nagarik-suraksha-sanhita-2023
- Comparison Summary BNSS to CrPC - BPRD: https://bprd.nic.in/uploads/pdf/Comparison%20summary%20BNSS%20to%20CrPC.pdf
- Significant Changes in BNSS - Manupatra Academy: https://www.manupatracademy.com/assets/pdf/Significant-Changes.pdf
Disclaimer: This article is for educational and informational purposes only. It does not constitute legal advice. The case laws and statutory provisions discussed are based on publicly available sources and judicial databases. Readers should verify current legal positions from official sources before relying on them for any legal proceedings.
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