Post the re-enactment of CrPC 1973, there was ambiguity in the jurisprudential understanding of ‘special reasons’ for imposing the death sentence.  The Supreme Court in Rajendra Prasad v. State of Uttar Pradesh, February 1979 dealt with the legal policy on sentencing discretion and also comprehensively discussed the meaning of ‘special reasons’ for inflicting death sentence on exceptional grounds. The Court departed from retributive theory and emphasized on the deterrence and reformative theory as the social goals. Furthermore, the Court held that the ‘special reasons’ required to impose the capital punishment must not relate to the crime, but focus must be on the criminal.