In Bachan Singh v. State of Punjab (1980) judgements of the Constitutional Bench of the Supreme Court of India, the 'rarest of the rare' principle in the award of death penalty was first laid down. In Gopalanachari v. State of Kerala, the Supreme Court analysed relationship between fundamental rights and preventive detention. In Dr. Upendra Baxi v. State of U.P., the Supreme Court held that it was happy to note that the State Government had responded to the various directions and had taken steps with a view to improving the living conditions of the inmates of jail. In Tukaram v. State of Maharashtra, the Supreme Court defined custodial rape, the amendment shifted the burden of proof from the accuser to the accused once intercourse was established. It also added provisions for in-camera trials.