The famous case of Bachan Singh versus State of Punjab, decided 32 years ago by the apex court, had dealt with two issues - the first pertained to the constitutional validity of the death penalty for murder as provided in Section 302 of the IPC and second one was on "sentencing procedure embodied in sub-section (3) of Section 354 of the CrPC, 1973."
It had dealt with aggravating and mitigating circumstances of the case. While aggravating circumstances deal with the offence, the mitigating circumstances relate to the offender.