Emphasising lack of uniformity in approach and differences of opinion on how to proceed and analyse mitigating circumstances, while awarding death sentence to a convict by courts, the Supreme Court on Monday referred the issue to a five-judge bench Constitution bench for a comprehensive and authoritative adjudication.Emphasising lack of uniformity in approach and differences of opinion on how to proceed and analyse mitigating circumstances, while awarding death sentence to a convict by courts, the Supreme Court on Monday referred the issue to a five-judge bench Constitution bench for a comprehensive and authoritative adjudication.