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.