The Code also pointed out that whenever death sentence is imposed, the sentence shall be a direction to the accused that he shall be hanged by the neck till he is dead.

In Deena vs. State, AIR 1983 S.C. which is known as ‘hanging by noose case’, Chief Justice Chandrachud examined various methods of executing an accused who is sentenced to death after examining methods of capital punishment in various countries.

Justice Chandrachud pointed out that hanging by the noose which is the mode of execution adopted in India to be the least painful method of executing death sentence.

The execution of death sentence by hanging was questioned for the first time in this case in respect of its constitutionality and the court held that it was intra vires, of the Constitution of India.