In the case of Rishi Malhotra v. Union of India, October 2017, hanging as a mode 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.