sentence was commuted to life imprisonment after taking into consideration the possibility of reform and rehabilitation of the appellant that was evidenced by his good conduct in prison. Methods of execution Execution by hanging Hanging is an ancient method of execution which was a part of the Roman law, Anglo-Saxon law, English law, French law, and German law. Hanging as a punishment was a prevalent and standard mode of execution until the abolition of capital punishment in the United Kingdom in 1965. This traditional method of execution may involve suspending the convict from a gallows or crossbeam until death occurs from asphyxia, or it may be that the condemned person stands on a trapdoor and when the trap is released he falls a couple of metres until stopped by the rope tied around his neck or a knot in the noose helps jerk back the victim's head sharply enough to break the neck. This mode of execution is widely debated and the Law Commission in its report in 2015 stated that the shift from hanging to more advanced methods execution must be made in India. In the case of Deena v Union of India, September 1983 the constitutional validity of execution by hanging was challenged on grounds that hanging as contemplated under Section 354(5) Cr.P.C was barbarous and inhuman and thereby infringed on the right to life of the person. The court discussed various historical influences as well as the reports of the law commission and held that execution by hanging was a fair, just and reasonable procedure within the meaning of Article 21 and hence is constitutional. In the case of Rishi Malhotra v. Union of India, October 2017, hanging as a method of execution was challenged in a writ petition and it was argued that Section 354(5) CrPC was not only barbaric, inhuman and cruel but also against the resolutions adopted by the United Nations Economic & Social Council (ECOSOC). This case brought out the discussion around the shift from hanging to other advanced methods of execution in various developed countries. It was also discussed that as per international standard, execution should be as quick and as simple as possible and should produce immediate unconsciousness passing quickly into death. Execution by shooting Apart from hanging, the other method of execution allowed under the Indian law is shooting, which is provided for under the Army Act, Navy Act, and