A/HRC/4/20 page 31 134 Previous reports on the Special Rapporteur have also discussed the prohibition of mandatory death sentences briefly. A/61/311, para. 57; E/CN.4/2005/7, paras. 63-64; E/CN.4/2002/74, paras. 114, 120; E/CN.4/2001/9, para. 83; A/55/288, paras. 34, 36; E/CN.4/2000/3, paras. 70, 73, 98; E/CN.4/1999/39, paras. 63, 82. 135 CHR Res. 2005/59, para. 7 (f). 136 The first national court to strike down the mandatory death penalty as a violation of rights was that of the United States Supreme Court in 1976. Woodson et al. v. North Carolina, 428 U.S. 280 (1976); Sumner v. Shuman, 483 U.S. 66 (1987) (clarifying that the holding in Woodson did not have exceptions). The Supreme Court of India invalidated that country’s last remaining mandatory death penalty law in 1983, and the Constitutional Court of Uganda followed suit in 2005. Mithu v. State of Pubjab, 2 S.C.R. 690 (1983); Susan Kigula and 416 others v. Attorney General, Constitutional Petition No. 6 of 2003, Judgement of 10 June 2005. Influenced by the reasoning of the US and Indian decisions, international treaty bodies began contributing to the jurisprudence in the mid-1990s. The HRC first found a mandatory death penalty law incompatible with the ICCPR in 1995 and did so in more general terms in 2000. Lubuto v. Zambia, Human Rights Committee, No. 390/1990 (1995); Thompson v. Saint Vincent, Human Rights Committee, No. 806/1998 (2000). The Inter-American Commission on Human Rights reached the same conclusion in 1999. Rudolph Baptiste v. Grenada, Inter-American Commission on Human Rights, Case 11.743, Report No. 38/00 (1999). The Inter-American Court of Human rights confirmed this jurisprudence in 2002. Hilaire, Constantine and Benjamin et al. v. Trinidad and Tobago, Series C, No. 94 (21 June 2002). The most influential recent judgements have been those of the Judicial Committee of the Privy Council. The Privy Council first considered the constitutionality of a mandatory death penalty law in Ong Ah Chuan v. Public Prosecutor (1980) and found that law constitutional. Ong Ah Chuan v. Public Prosecutor (1980) 3 WLR 855 (Privy Council; appeals from the Court of Criminal Appeals of Singapore). However, in subsequent cases the Privy Council has rejected this line of reasoning and established that the mandatory death penalty is incompatible with human rights. The question of whether the mandatory death penalty violated individual human rights was settled by 2002. Reyes v. The Queen [2002] 2 App. Cas. 235 (P.C.), judgement of 11 March 2002 (Belize); Queen v. Hughes [2002] 2 App. Cas. 259 (P.C.), judgement of March 2002; Fox v. The Queen [2002] 2 App. Cas. 284 (P.C.), judgement of March 2002. See also Eastern Caribbean Court of Appeal, Spence and Hughes v. The Queen, Crim. App. Nos. 20 of 1998 and 14 of 1997, judgement of 2 April 2001. Later cases have primarily concerned questions of whether those rights were enforceable under particular constitutional schemes. See Joanna Harrington, The Challenge to the Mandatory Death Penalty in the Commonwealth Caribbean, American Journal of International Law, Vol. 98, No. 1 (January 2004), pp. 126-140. In a 2006 case, the Privy Council noted that the evolution of its jurisprudence was due not to the changing content of the law but to the gradual process by which judges came to understand that law: “It is … clear that it took some time for the legal effect of entrenched human rights guarantees to be appreciated, not because the meaning of the rights