as standard to impose the death sentences. The Court categorically stated the relevance and desirability of 'public opinion', is no more important in the jurisprudence and adjudication of death sentences. It also disregarded the social necessity as criteria for the infliction of death sentence. The Court asserted that the judiciary is a counter-majoritarian institution and individual rights should be given more importance. Sangeet v. State of Haryana, November 2012 The Supreme Court in Sangeet v. State of Haryana, November 2012, seriously expressed reservation regarding inconsistent and incoherent application of sentencing policy with respect to analyzing the aggravating and mitigating circumstances. The court critiqued the process of drawing a balance sheet of aggravating and mitigating circumstances and stated that they cannot be compared with each other as each of the factors are two distinct and different constituents of the incident. Moreover, the court itself admitted that the doctrine of rarest of rare is not followed properly and departed from the 'principled sentencing' to a judge-centric sentencing policy of the death sentence. Furthermore, the Supreme Court also critiqued the categorization of the crime (manner of commission of murder, motive for commission of murder, antisocial or socially abhorrent nature of the crime, magnitude of crime and personality of victim of murder) propounded in Machhi Singh v. State of Punjab, July 1983. The Court noted that Machi Singh standardization of the crime considerably enlarged the scope of imposing death sentence, which was severely restricted in Bachan Singh v. State of Punjab, May 1980 and also affirmed that the standardization shall not be taken as absolute or inflexible rule in the sentencing policy of the death sentence. Shanker Kisanrao Khade v. State of Maharashtra, April 2013 The Supreme Court in Shanker Kisanrao Khade v. State of Maharashtra, April 2013, acknowledged that the difficulty in the application of 'rarest of rare' since there is lack of empirical data for making twofold comparison between murder (not attracting death penalty) and murder (attracting penalty). The Court also envisaged a new triple test, while awarding the death sentence and it required 'crime test'. 'criminal test' and the 'rarest of rare test' and this test was not equivalent to 'balance test'. The Court stated that the death sentence can only be inflicted, once they satisfy the 'crime test 100%', 'criminal test 0%' (there must no mitigating circumstances favouring the accused) such as possibility of reform, young age of the accused,