The doctrine of “rarest of rare cases” was evolved by the Court in the case of:

Bachan Singh v. State of Punjab, the mandatory death sentence under Section 303 of IPC was declared unconstitutional and removed from the Code. This Section stated that any criminal who has been sentenced to life imprisonment, committed a murder while in custody would be sentenced to death. In Gyan Kaur v. State of Punjab, a five-judge Constitutional Bench held that 'Right to Life' as stated under Article 21 of the Indian Constitution, does not include the 'Right to die'. Dileep Singh v. State of Bihar: It was therefore held that either there was no consent or the consent was involuntary. Thus, according to the trial Court, it was a case of having sexual intercourse against the will of the victim girl or without her consent. If so, irrespective of the age of the girl, the offence is deemed to be committed.  Mohd. Yakub v. State of Maharashtra is a case that deals with the offense of attempting to commit an offense under Section 511 of the Indian Penal Code. The Supreme Court held that the prosecution had failed to prove that the respondents had taken any step towards the commission of the offense.