A BUDDHIST PERSPECTIVE ON THE DEATH PENALTY (original) (raw)

A BUDDHIST PERSPECTIVE ON THE DEATH PENALTY OF COMPASSION AND CAPITAL PUNISHMENT

By DAMIEN P. HORIGAN

The American Journal of Jurisprudence
Volume 41(1996)
P.271-288


                            P.271

                      I. INTRODUCTION

        There   is  a  global   trend  against   capital
    punishment.  Most nations in the developed world and
    an increasing  number  of nations  in the developing
    world   have   officially    abolished   the   death
    penalty.(1)  Similarly,  there  is  an  abolitionist
    movement  in  the  realm  of  international  law.(2)
    However, matters  are quite different  in the United
    States(3) where the United States  Supreme  Court in
    Gregg  v.  Georgia(4) permitted  the  resumption  of
    executions  by the states  after the hiatus  brought
    about by Furman v. Georgia.(5)

        If public opinion  polls are to be believed, the
    general   concept  of  capital  punishment   remains
    popular in the United States today.  Politicians are
    well aware of this.  In the spring  of 1995 New York
    rejoined the ranks of states with the death penalty.
    A majority  of states  have  laws providing  for the
    death  penalty  even  though  the  number  of actual
    executions  remains relatively  low when compared to
    the population  of inmates  on death rows across the
    nation.(6)

         In recent  years  the Supreme  Court  has repe-
    atedly  come out in favor of the death  penalty.
    For   instance,  the  mentally   retarded   may   be
    executed.(7) Likewise, minors  may  be  executed.(8)
    Such decisions go
    -----------------

        1. Charles Humana, World Human Rights (1992).

        2.  William  A.  Schabas, The  Abolition  of the
    Death Penalty in International Law (1993).

        3. An informative overview of capital punishment
    in America  can be found  in Amnesty  International,
    United States of America: The Death Penalty  (1987).

        4.  428 U.S. 153, 96 S.  Ct.  2909, 49 L. Ed. 2d
    859 (1976).

        5.  408 U.S. 238, 92 S.  Ct.  2726, 33 L. Ed. 2d
    346 (1972).

        6.  Tom Morganthau  et al, "Condemned  to Life,"
    Newsweek, Aug.  7, 1995, p.  18;  David  A.  Kaplan,
    "Anger and Ambivalence," Newsweek, Aug.  7, 1995, p.
    24;   Rebecca   Westerfield,  "The  Death   Penalty:
    Impending  Challenges, "  22  Human  Rights  (Winter
    1995), p. 40; Michael Ross, "A View from Death Row,"
    22 Human Rights (Summer 1995), p. 20.

        7.  Penry v. Lynaugh, 492 U.S.  302, 109 S.  Ct.
    2934, 106 L.  Ed.  2d 256  (1989).  See  also, Emily
    Fabrycki Reed, The Penry Penalty: Capital Punishment
    and Offenders with Mental Retardation (1993).

        8.  Thompson v.  Oklahoma, 487 U.S.  815, 108 S.
    Ct.  2687, 101  L.  Ed.  2d 702  (1988).  See  also,
    Suzanne D.  Strater, "The Juvenile Death Penalty: In
    the Best  Interests  of the Child?" 22 Human  Rights
    (Spring 1995), p. 10.

                            P.272


    against what appears to be the general evolution  of
    international law.(9)

        Yet  perhaps  the most  dramatic  and disturbing
    example of the Supreme Court's recent support of the
    death penalty  is Herrera  v.  Collins(10) where the
    existence  of evidence  supporting  the petitioner's
    claim of actual innocence was not proper grounds for
    federal  habeas  corpus  relief.  In other words, in
    Herrera, the Supreme  Court  was willing  to allow a
    person  who was possibly  not guilty  to be executed
    despite  documented  claims of actual innocence  and
    related  federal constitutional  arguments  based on
    the Eighth Amendment's prohibition against cruel and
    unusual  punishment  and  the Fifth  and  Fourteenth
    Amendments' guarantee of due process of law.

        The  implications  of Herrera(11) are especially
    tragic when one realizes  that a surprisingly  large
    number of Americans  have been wrongly convicted  of
    capital crimes.  Some of these individuals have also
    been  executed.(12)  In  the  United   Kingdom,  the
    execution  of a man who later turned out to possibly
    be not guilty served as an impetus toward doing away
    with   capital   punishment   for  murder   in  that
    country.(13) In  any  event, as  is  the  case  with
    capital  punishment  in the United States generally,
    race and class  (14) play a role in determining  who
    is more likely to be executed in spite of innocence.

        Regardless  of how the current Supreme Court may
    interpret  the Constitution, as Mr.  Justice William
    Brennan once pointed out: "At
    ------------

        9.   The  Abolition  of  the  Death  Penalty  in
    International Law.

        10. 506 U.S. 390, 113 S. Ct.  853, 122 L. Ed. 2d
    203 (1993)

        11.  As Mr.  Justice  Harry  Blackmun  put it so
    well: "The execution  of a person  who can show that
    he  is innocent  comes  perilously  close  to simple
    murder." Herrera, 506 U.S.  390, --; 113 S. Ct. 853,
    884;  122  L.   Ed.   2d  203,  246  (Blackmun,  J.,
    dissenting).

        12.  Michael  L.  Radlet  et  al,  In  Spite  of
    Innocence: Erroneous  Convictions  in Capital  Cases
    (1992).  See also, American  Civil Liberties  Union,
    Innocence   and  the  Death  Penalty  (ACLU  Capital
    Punishment Project Fact Sheet, June 1995).

        13. R. v. Evans, [1950] 1 All ER 610, 66 TLR (Pt
    1) 629, 34 Cr App Rep 72, [1950]  WN 111.  See also,
    James B.  Christoph, Capital Punishment  and British
    Politics: The British Movement  to Abolish the Death
    Penalty  1947-1957  (1962).  Ironically, one  of the
    prosecutors   in  Evans  was  a  well-known  English
    Buddhist  writer  and  lay  leader  named  Christmas
    Humphreys  (1901-1983).  Humphreys  would  go  on to
    become a particularly  liberal  judge at the Central
    Criminal  Court  i.e., "the  Old Bailey."  Christmas
    Humprheys'  father  was the noted jurist Sir Travers
    Humphreys  (1867-1956) .  See  generally,  Christmas
    Humphreys,   Both   Sides   of   the   Circle:   The
    Autobiography of Christmas Numphreys (1978)
    Christmas     Humphreys,     "The     Duties     and
    Responsibilities of Prosecuting Counsel, Grim.  L.R.
    (1955), p. 739.

        14.  See, e.g., Adalberto Aguirre, Jr. and David
    V.  Baker, Race, Racism and the Death Penalty in the
    United  States (1991);  Michael  Ross, "Is the Death
    Penalty  Racist?" 21 Human Rights (Summer  1994), p.
    32.

                            P.273


    bottom, the battle [over the death penalty] has been
    waged on moral  grounds."(15) Taking  this statement
    from  Brennan  as a cue, it is  useful  to  look  at
    religious perspectives on the death penalty.

        It  should  perhaps  come  as no  surprise  that
    within  the  United  States,  Jewish  and  Christian
    religious  bodies  have not spoken with one voice on
    capital punishment.(16) In the broad Judeo-Christian
    tradition, biblical  passages  have been  quoted  by
    retentionists  and abolitionists alike in support of
    their respective  positions.(17) While  it might  be
    one thing for certain  Jews(18) to quote  the Hebrew
    Bible  in  support  of  capital  punishment,  it  is
    striking  that  so many Christians  support  capital
    punishment.  After all, Jesus (4 BC?-29 AD?) remains
    the world's most famous executed criminal defendant.

        Be that as it may, very little  has been written
    regarding Buddhist views on capital punishment.  The
    author intends to help remedy this deficiency.  What
    follows, therefore, is a Buddhist perspective on the
    death  penalty  based  upon  Buddhist   thought  and
    history.  This article  should be seen as being just
    that.  In other words, what is about to be presented
    is merely one possible  perspective, albeit one that
    has considerable  support  in the corpus of Buddhist
    literature  and  the  experience  of Buddhism  as  a
    living religion  existing  in various cultures  over
    the past two and a half millennia.

                 II.   BUDDHIST TEACHINGS

        Buddhism(19)  is  a  rich  tradition   with   an
    extensive  corpus  of  religious(20) literature.(21)
    This literature  has been referred  to by the author
    in

    ----------
        15. Furman, 408 U.S.  238, 296; 92 S.  Ct. 2726,
    2755;   33  L.   Ed.   2d  346,  382  (Brennan,  J.,
    concurring).

        16.  Nevertheless, many  mainstream  Jewish  and
    Christian  denominations  in the United States  have
    gone  on  record  as  opposing  the  death  penalty.
    Michael   Kronen-wetter,   Capital   Punishment:   A
    Reference   Handbook  (Contemporary   World  Issues,
    1993), pp. 59-61, 70.

        17. Ibid., pp. 150-155.

        18.   Incidentally,  in   1954   Israel   itself
    abolished   capital   punishment   except   for  the
    punishment  of Nazi war crimes.  World Human  Rights
    Guide, p. 158.

        19.  The  author  will  consider  Buddhism  as a
    whole.  It is the author's  opinion  that Theravada,
    Mahayana, and Vajrayana--the  three  major  forms of
    Buddhism in existence today--all share a significant
    common ground.  There is an unfortunate  tendency on
    the  part  of  some  scholars  to overemphasize  the
    differences   among  the  three  forms.   For  brief
    definitions  of Theravada, Mahayana, and  Vajrayana,
    refer  to  Ingrid   Fischer-Schreiber   et  al,  The
    Encyclopedia  of  Eastern  Philosophy  and  Religion
    (Stephan  Schuhmacher  et  al,  trans.  1994) ,  pp.
    215-16, 369, 398-99.

        20.  The author defines Buddhism as a "religion"
    even though Buddhism  lacks a notion  of "God" along
    the lines  of what  is found  in theistic  religions
    like Judaism,

                             P.274


    developing a systematic Buddhist perspective  on the
    death  penalty.(22) The nature  and  purpose  of the
    texts(23)vary, but the major themes of the texts point
    toward a definite stance which is clearly within the
    spirit  of  the  Buddhist   outlook   on  the  human
    condition.

    A. Panca-sila

        A logical  starting  point  from which  to begin
    considering  a Buddhist  perspective  on  the  death
    penalty  would  be  Buddhism's  most  basic  set  of
    training  rules for personal  spiritual  development
    known  as the  panca-sila(24) or five  precepts.(25)
    These  basic  rules  of good  conduct  are  for  all
    Buddhists,  lay  or  ordained.(26)
    ---------
    Christianity, and  Islam.  This  is similar  to  how
    Buddhism is viewed in American law. See, e.g., Welsh
    v. U.S., 398 U.S. 333, 357, 90 S. Ct. 1792, 1805, 26
    L. Ed.  2d 308, 328 (1970) (Harlan, J., concurring);
    U.S.  v. Seeger, 380 U.S.  163, 174, 85 S.  Ct. 850,
    858, 13  L.  Ed.  2d  733, 742  (1965);  Torcaso  v.
    Watkins, 367 U.S. 488, 495, 81 S.  Ct. 1680, 1684, 6
    L.  Ed. 2d 982, 987 (1961).  See also, Cruz v. Beto,
    405  U.S.  319, 92 S.  Ct.  1079, 31 L.  Ed.  2d 263
    (1972) (per curiam).


        21.  The  author  has  examined  mostly  English
    translations   of  canonical   works   from  various
    versions of the Buddhist Canon (Sanskrit: Tripitaka;
    Pali: Tipitaka). Given the immense size of the Canon
    as well as the fact that  only certain  portions  of
    the Canon are currently available  in either English
    or  other  European  languages, the  present  survey
    should  be treated  as being indicative  rather than
    exhaustive.  For more information  on the nature  of
    the  Buddhist  Canon, see  generally  Maha  Sthavira
    Sangharakshita  (Venerable), The Eternal  Legacy: An
    Introduction to the Canonical Literature of Buddhism
    (1985) ;  Kogen  Mizuno,  Buddhist  Sutras:  Origin,
    Development, Transmission  (Morio  Takanashi  et al,
    trans.   1982) ;  White  Lotus  Co.,  Guide  to  the
    Tipitaka: AN  INTRODUCTION  TO  THE  BUDDHIST  CANON
    (Martin Perenchio  et al, eds.  1993);  Bukkyo Dendo
    Kyokai, An Introduction  to the Buddhist  Canon: 139
    Buddhist  Scriptures  (Shoyu Hanayama, ed.  and R.W.
    Giebel, trans. 1986) [In English & Japanese].

        22. It is worth noting that despite the vastness
    of  Buddhist   literature,  canonical   as  well  as
    non-canonical, ultimately the Buddhist experience of
    life lies beyond anything written.  Buddhist insight
    transcends    language   itself.    As   Bodhidharma
    (470?-543?), a famous South Indian Buddhist  monk who
    was active in China, once wrote:

        "The ultimate  Truth is beyond words.  Doctrines
        are  words.  They're  not  the  Way.  The Way is
        wordless."  Bodhidharma,  The  Zen  Teaching  of
        Bodhidharma (Red Pine trans., 1989), p. 31.

        23.  The texts discussed in this article will be
    referred  to  in an order  that  does  not  strictly
    consider   the   possible   dates   of  composition.
    Likewise, the texts represent  different  sects  and
    schools of Buddhism.

        24.  Most key Buddhist terms referred to in this
    paper will include transliterations  of the Sanskrit
    versions.

        25.   For  a  general  discussion  of  the  five
    precepts  see,  (Bhikkhu) Bodhi, Going  for  Refuge:
    Taking  the Precepts  (The  Wheel  Publication  Nos.
    282-284,  1981).  See  also,  Nandasenda  Ratnapala,
    Crime  and  Punishment  in  the  Buddhist  Tradition
    (1993), pp. 72-73.

        For some thoughts on the tension between capital
    punishment and the five precepts,


                            P.275


        The  very  first, and arguably  most  important,
    precept  is the  training  rule  of abstaining  from
    taking  life.  The four other  training  rules  are:
    abstaining from taking what is not given; abstaining
    from  sexual  misconduct;   abstaining   from  false
    speech; and abstaining from intoxicants.

        Abstaining   from   the   destruction   of  life
    encourages    the    development    of    compassion
    (karuna) (27) for  all  beings.  Moreover,  Buddhism
    teaches  that all sentient  beings  (sattva)(28) are
    fundamentally good. All sentient beings possess what
    is  known  as  Buddha-nature  (buddhata).(29) Having
    Buddha-nature  means  that all sentient  beings  can
    eventually      realize      enlightenment/awakening
    (bodhi) (30)  and  thereby   become  Buddhas   i.e.,
    Awakened     Ones.(31)    Hence,     Buddhism     is
    universalistic.   Everyone   has   great   spiritual
    potential  waiting  to be unleashed  no  matter  how
    depraved they might look.

        All life is to be treasured.  It matters not how
    lowly  such life may seem.  Treasuring  the lives of
    those  who, in many cases, have not valued  lives of
    others is an act of spiritual courage. This notion
    ---------

    see  Andrew   Huxley,  Sanction   in  the  Theravada
    Buddhist Kingdoms of S.E. Asia (1992), pp. 335, 366.

        26.  Ordained  Buddhists  viz., monks  and nuns,
    traditionally   have  additional  sets  of  training
    rules.  Edward  Conze,  Buddhism:  Its  Essence  and
    Development  (1959) (1951), p.  54.  Such rules also
    provided Buddhist monastic orders with the authority
    for  disciplining  monks  and nuns.  See  generally,
    Crime and Punishment in the Buddhist Tradition; M.B.
    Voyce, "The Legal Authority  of the Buddha  over the
    Buddhist  Order  of  Monks," 1  J.Of  L.  & Religion
    (1983), p. 307; M.B. Voyce, "The Communal Discipline
    of the Buddhist  Order  of Monks: The 'Sanction'  of
    the Vinaya Pitaka," 29 Am. J. Juris. (1984), p. 123.
    Such monastic  law should be distinguished  from the
    influence  of Buddhism  on more secular  Asian legal
    thought.  One place where Buddhism continues to have
    some  influence  on the  national  legal  system  is
    Thailand. Frank E. Reynolds, "Dhamma in Dispute: The
    Interaction of Religion and Law in Thailand," 28 Law
    & Soc'y. R. (1994), p. 433.

        27.  The Encyclopedia  of Eastern Philosophy and
    Religion,  pp.   176-77;   John  Grimes,  A  Concise
    Dictionary  of  Indian  Philosophy:  Sanskrit  Terms
    Defined in English (1989), pp. 172-73.

        28.   Yuho   Yokoi,  The  Japanese-English   Zen
    Buddhist  Dictionary  (1991), pp.  705, 807;  Arthur
    Anthony Macdonell, A Practical  Sanskrit Dictionary:
    With Transliteration, Accentuation, and Etymological
    Analysis Throughout (1965) (1924), p.  330.  Purists
    may note that sattva  is a neuter  noun.  Hence, the
    plural in the nominative case should be sattvani.

        29.  Whether  this also applies  to non-sentient
    beings is a matter of some rather scholastic debate.
    The Encyclopedia of Eastern Philosophy and Religion,
    p. 49. Such debate shall remain outside the scope of
    the present paper.

        30. Ibid., p. 37.


        31.   A  Practical   Sanskrit  Dictionary:  With
    Transliteration,   Accentuation,  and   Etymological
    Analysis Throughout, p. 196.

                            P.276


    supports nonviolence/non-harming  (ahimsa)(32) which
    leads to the advocation  of such wholesome causes as
    world  peace(33)  and  vegetarianism.(34)  Taking  a
    strong stance against the death penalty is a logical
    outgrowth  of any religion or philosophy  based upon
    nonviolence.(35)

        Another  aspect  of  ahimsa  is  the  notion  of
    karma, (36) "action"  or  "deed."  At  the  risk  of
    over-simplification, there  is good  as well  as bad
    karma.  We are influenced by karma from the past and
    we create  new karma in acts of free will as we live
    our lives. Killing is simply bad karma.

        The author  will now turn to additional  textual
    support  for a Buddhist  position  against all forms
    and cases of capital punishment

    B. THE DHAMMAPADA

        One of the most important  religious  texts  for
    Buddhism is a poetic collection  of aphorisms  known
    as the Dhammapada or Dharmapada.(37)
    -------------

        32. Ahimsa is also a central concept in Hinduism
    and even  more  so in Jainism.  The Encyclopedia  of
    Eastern  Philosophy  and Religion, p.  5;  A Concise
    Dictionary  of  Indian  Philosophy, p.  17.  In this
    century, ahimsa was a guiding principle for Mohandas
    Karamchand  Gandhi  (1869-1948) and later for Martin
    Luther  King, Jr.  (1929-1968).  See, Dennis Dalton,
    Mahatma Gandhi: Nonviolent Power in Action (1993).

        33.  See, e.g., Inner Peace, World Peace: Essays
    on  Buddhism  and  Nonviolence  (Kenneth  Kraft, ed.
    1992)   ;    Buddhism    and    Nonviolent    Global
    Problem-Solving: Ulan Bator Explorations  (Glenn  D.
    Paige and Sarah Gilliatt, eds. 1991).

        34.  Only a minority  of Buddhists  are actually
    vegetarian.  Nevertheless, vegetarianism  does  find
    strong  support  among  the monks and nuns of China,
    Korea, and Vietnam.  See Philip  Kapleau, To Cherish
    All Life: A Buddhist  Case  for Becoming  Vegetarian
    (1982).

        35.  Admittedly, there  have been some  attempts
    during  the  long  history  of Buddhism  to  provide
    Buddhist  justifications  for killing  human  beings
    especially   in  times  of  war.   See,  e.g.,  Paul
    Demieville,  "Le  Bouddhisme  et  la  Guerre,  "  11
    Bibliotheque   de  l'Institut   des  Hautes   Etudes
    Chinoises  (1957) ,  p.   347;  Capt.   Lawrence  P.
    Rockwood,  "Apology  of  a  Buddhist  Soldier,  "  5
    Tricycle: The Buddhist Review (Spring 1996), p.  71.
    Ritual  suicide  has also  found  a place, albeit  a
    small  one, in Buddhism.  A recent  immolation  case
    reminiscent  of the  1960s  took  place  in Vietnam.
    "Notes on Church-State  Affairs--Vietnam," 36 J.  of
    Church  and  State  (1994),  pp.  222-23.  Likewise,
    abortion is tolerated in an interesting  way by some
    Buddhists.  William  LaFleur,  "The  Cult  of  Jizo:
    Abortion Practices  in Japan and What They can Teach
    the West," 4 Tricycle: The Buddhist  Review  (Summer
    1995), p. 40.

        Naturally, on one  level, there  is a difference
    between killing the guilty and killing the innocent.
    Yet, even a person who commits the most heinous acts
    remains a human being.

        36.  It is arguably more accurate  to say karman
    which is the nominative case of this neuter Sanskrit
    noun.  See  A  Practical  Sanskrit  Dictionary: With
    Transliteration,   Accentuation,  and   Etymological
    Analysis  Throughout,  p.  64.   However,  "karma, "
    without  the final "n" has already become an English
    word listed  in many dictionaries.  Here it will  be
    treated as such.

        37.  There are quite  a few translations  of the
    Dhammapada into English. The

                             P.277


    This  work  is  preserved  in Pali(38) and  in other
    ancient languages.(39) The title means roughly "Path
    of   Dhamma"   (Sanskrit:   Dharma)  .    The   term
    dharma/dhamma  can  be translated  in any number  of
    ways   depending   upon   the   context.   "Law,   "
    "righteousness," "merit,"  "quality,"  "cause,"  and
    "religious   teachings"   are  among   some  of  the
    approximate  meanings  of this key concept in Indian
    thought.(40)

        The  initial   verses  of  Chapter   10  of  the
    Dhammapada   speak   of  killing:  "Everyone   fears
    punishment;  everyone  fears  death, just as you do.
    Therefore  do not kill  or cause  to kill.  Everyone
    fears punishment;  everyone  loves  life, as you do.
    Therefore do not kill or cause to kill."(41)

        In  Chapter   26,  the  final  chapter   of  the
    Dhammapada, we find a related passage: "Him I call a
    brahmin(42) who has put aside weapons
    ---------------

    author has relied mostly upon The Dhammapada (Eknath
    Easwaran, trans. 1985). Other translations consulted
    include:  The  Dhammapada   (John  Boss  Carter  and
    Mahinda  Palihawadana, trans.  1987);  Juan Mascaro,
    The  Dhammapada:  The  Path  of  Perfection  (1973);
    (Venerable Sri) Achaya Buddharakkhita, Dhammapada: A
    Practical Guide to Right Living (1959).

        38.  Pali is an ancient Indian language  closely
    related  to  Sanskrit.  A body  of  religious  texts
    handed  down in Pali forms the scriptural  basis for
    Theravada  Buddhism, the  main  school  of  Buddhism
    found today  in Sri Lanka, Burma, Thailand, Laos and
    Cambodia.   Theravada   Buddhism   also  has  lesser
    presence  in other  parts  of Asia.  See  generally,
    Buddhism: Its Essence  and Development.  As for some
    technical  concerns  about working with texts in the
    Pali Canon, see K.R. Norman, "Pali Philology and the
    Study  of Buddhism," in The Buddhist  Forum: Seminar
    Papers 1987-1988  (Tadeusz Skorupski, ed.  1990), p.
    31; K.R. Norman, "The Pall Language and Scriptures,"
    in The  Buddhist  Heritage  (Tadeusz  Skorupski, ed.
    1989), p. 29.

        For a study of the influence  of Fali literature
    on the legal history of much of Southeast  Asia, see
    Andrew Huxley, "Sanction  in the Theravada  Buddhist
    Kingdoms of S.E.  Asia," Recueils de la Societe Jean
    Bodin (1992), p. 335.

        39. Various versions of the Dhammapada have been
    preserved  in  Pali,  Gandhari,  Sanskrit, Classical
    Chinese, and Classical  Tibetan.  From such versions
    modern  translations  into a considerable  number of
    contemporary  Asian and Western languages  have been
    made. Kogen Mizuno, "Dharmapadas of Various Buddhist
    Schools, "  in  A.K.  Narain, Studies  in  Pali  and
    Buddhism: A Memorial  Volume  in  Honor  of  Bhikkhu
    Jagdish Kashyap (1979), p. 255.

        40.  A Concise Dictionary  of Indian Philosophy:
    Sanskrit Terms Defined in English, pp. 113-14.

        41. The Dhammapada, p. 111.

        42.  Here  the term brahmin  is being  used in a
    Buddhist  sense  as opposed  to the  standard  Hindu
    understanding of the term. Thus, in the Dhammapada a
    brahmin  is one  who  has awakened  spiritually.  In
    mainstream  Hinduism, however, a brahmin is merely a
    member of the priestly caste. Ibid., p. 188.

        Incidentally, "brahmin"  is actually  an English
    word derived from the Sanskrit brahmana which is, in
    turn, derived from the Vedic brahman. This point was
    kindly  explained  to me in some detail  on November
    22, 1995, by Dr. Waiter Harding Maurer, Professor of
    Sanskrit, University of Hawaii at Manoa.

                            P.278


    and  renounced  violence  toward  all creatures.  He
    neither kills nor helps others to kill."(43)

    C. Janasandha-Jataka

        This  jataka(44) is a story(45) Said  to be told
    by the Buddha  to the  King  of Kosala.(46) It tells
    the tale of a certain  Prince Janasandha, the son of
    King Brahmadatta of Benares:

          Now when [Prince Janasandha]  came of age, and
          had returned from Takkasila, where he had been
          educated in all accomplishments, the king gave
          a general  pardon  to all prisoners, and  gave
          him  the  viceroyalty.   Afterwards  when  his
          father  died,  he  became  king, and  then  he
          caused to be built six almonries.... There day
          by  day  he  used  to distribute  six  hundred
          pieces of money and stirred  up all India with
          his almsgiving: the prison doors he opened for
          good  and  all, the  places  of  execution  he
          destroyed....(47)

        Abolition  of the  death  penalty  is  a regular
    theme in Buddhism, as we shall see below.

    D. Rajaparikatha-ratnamala

        The  Rajaparikatha-ratnamala  or  "The  Precious
    Garland  of Advice  for  the King"(48) is a treatise
    attributed  to  the  famous  South  Indian  Buddhist
    philosopher  Nagarjuna  (2nd or 3rd century AD).(49)
    In this work on Buddhist statecraft, Nagarjuna gives
    King Udayi  of the Satavahana  Dynasty  advice  on a
    variety   of  matters.(50)  Here  is  how  Nagarjuna
    handles capital punishment:
    ------------

        43. The Dhammapada, p. 197.

        44.  The jataka are reputed to be the stories of
    the  former  lives  of the historical  Buddha  i.e.,
    Gautama Siddhartha  (563?-483? BC).  Quasi-canonical
    in nature, the jataka  are  essentially  folk  tales
    that serve as a vehicle  for popularizing  Buddhism.
    See  The  Eternal  Legacy: An  Introduction  to  the
    Canonical Literature of Buddhism, pp. 55-66.

        45. The Jataka or Stories of the Buddha's Former
    Births, Vol.  4, Bk.  12 (E.B.  Cowell, ed.;  W.H.D.
    Rouse, trans. 1957) pp. 109-11.

        46.  Kosala was a kingdom in central  India with
    its  capital  in Savatthi, being  modern  day Saheth
    Maheth.  S.  Dhammika,  Middle  Land, Middle  Way: A
    Pilgrim's  Guide  to the Buddha's  India (1992), pp.
    163-78.

        47. The Jataka or Stories of the Buddha's Former
    Births, pp. 109-10.

        48.  Nagarjuna  and Kaysang  Gyatso  [Dalai Lama
    VII], The Precious  Garland and The Song of the Four
    Mindfulnesses (Jeffrey Hopkins et al, trans., 1975).

        49.  The Encyclopedia  of Eastern Philosophy and
    Religion, pp. 237-38.

        50.  For an interpretation  of the text and some
    background  on King Udayi, see Robert A.F.  Thurman,
    "Nagarjuna's Guidelines for Buddhist Social Action,"
    in  The  Path  of Compassion: Writings  on  Socially
    Engaged Buddhism (Fred Eppsteiner, ed. 1988); Robert
    A.F.   Thurman,  "Social  and  Cultural   Rights  in
    Buddhism," in

                            P279


        O King, through compassion you should always
        Generate an attitude of help
        Even for all those embodied beings
        Who have committed appalling sins.

        Especially generate compassion
        For those murderers, whose sins are horrible;
        Those of fallen nature are receptacles
        Of compassion from those whose nature is great....

        Once you have analysed the angry
        Murderers and recognised them well,
        You should banish them without
        Killing or tormenting them.(51)

        Banishment  or exile has been employed as a form
    of  sanction  in  various  pre-modern   Asian  legal
    systems.(52) Indeed, banishment has also been employed
    at times in the West.(53) Although banishment obviously
    entails psychological  and physical hardships, it is
    certainly to be preferred to death. Moreover, it can
    protect  the convicted  defendant  from the possible
    wrath of friends or family of the victim.

    E. Avatamsaka-sutra

        Another,  albeit  rather  unusual, treatment  of
    capital  punishment  comes  from  the lengthy(54) and
    highly symbolic  Avatamsaka-suutra(55) which is also
    known as the Buddhavatamsaka-sutra. This sutra or
    --------------
    Human Rights  and the World's  Religions  (Leroy  S.
    Rouner, ed. 1988), p.  148.  A brief overview of the
    Satavahana  Dynasty  can  be found  in Rama  Shankar
    Tripathi,  History  of  Ancient  India  (1942),  pp.
    191-201;   Etienne   Lamotte,  History   of   Indian
    Buddhism: From  the Origins  to the Saka  Era  (Sara
    Webb-Boin  and  Jean  Dantinne,  trans.  1988),  pp.
    474-81.

        51.  The Precious  Garland  and the Song  of the
    Four Mindfulnessess, pp. 66-67.

        52. See, e.g., Brian E. McKnight, The Quality of
    Mercy: Amnesties  and  Traditional  Chinese  Justice
    (1981).

        53. To name but two historical examples of exile
    as a form of punishment, what are now the U.S. state
    of Georgia and parts of Australia  were both used by
    the  British  Empire  as penal  colonies.  5 The New
    Encyclopaedia   Britannica:  Micropaedia  (15th  ed.
    1989), p. 201; Europa Publications, The Far East and
    Australasia (1995), p. 78. A contemporary attempt at
    using this sanction is described  in Peratrovich  v.
    State, 903 P.2d 1071 (Alaska Ct. App. 1995).

        An alternative to banishment would be probation.
    It has been argued  that this  was a common  type of
    sanction in maintaining  monastic  discipline  among
    Buddhist monks and nuns. Crime and Punishment in the
    Buddhist Tradition, pp.76-77.

        54.  To put things into proper  perspective, the
    Avatamsaka-sutra  by itself  is about as long as the
    whole  Hebrew  Bible.  See  generally,  The  Eternal
    Legacy: An Introduction  to the Canonical Literature
    of Buddhism, pp. 221-35.

        55.  This sutra became  the basis  for an entire
    East Asian sect of Buddhism  best known today by its
    Japanese name, Kegon. Shinsho Hanayama, A History of
    Japanese Buddhism (Kosho Yamamoto, trans. 1960), pp.
    27-30.


                            P.280


    scripture  tells the saga of a bodhisattva(56) named
    Sudhana-sresthidaraka,(57) or simply  Sudhana.  Sudhana
    is  on  a  pilgrimage  to  visit  various  spiritual
    teachers whom he is told to seek out for guidance.

        One of the teachers  is a king named  Anala.(58)
    King  Anala  lives  in  an  indescribably  beautiful
    palace in a far off, magical land; yet, he does have
    a crime  problem.  To keep the populace  in line, he
    conjures up frightful  images of prisoners  on which
    he passes judgement  and then has brutally  executed
    or otherwise severely tortured.

        In  reality,  the  King  does  not  harm  anyone
    because the prisoners  as well as the penal officers
    are all just illusions.  As the King explains to the
    seeker, these magical  projections  are meant  to be
    acts of compassion  to get actual  people to give up
    evil.

        Obviously, this passage is symbolic  and should,
    therefore, not be taken literally. It does, however,
    point  to the centrality  of compassion  in Buddhist
    legal  and social  thought.  Admittedly, the passage
    could  be  literally  construed  to support  capital
    punishment  along with deterrence as a goal of penal
    policy,(59) but, again, the notion of compassion  is
    more important  here.  In addition, the context must
    be remembered  viz., this is an especially  mystical
    text.

    F. Muga-Pakkha-Jataka

        This  jataka, said to be told  by the Buddha  to
    his monks, illustrates  that  punishment  can affect
    those who impose  it as well as those being directly
    punished.(60) The Muga-Pakkha-Jataka(61) makes  this
    point
    --------------

        56.   A  bodhisattva  in  Mahayana  Buddhism  is
    someone who has realized Enlightenment, but who vows
    to stay  in this  world  to help  others  to realize
    Enlightenment.    The   Encyclopedia    of   Eastern
    Philosophy  and  Religion,  pp.   39-40;  A  Concise
    Dictionary  of  Indian  Philosophy:  Sanskrit  Terms
    Defined in English, p. 99.

        57.    The   Japanese-English    Zen    Buddhist
    Dictionary, p. 847.

        58.  The author's account is based on The Flower
    Ornament  Scripture, The Text: A Translation  of the
    Gandavyuha, the Final  Book of the Avatamsaka  Sutra
    (Thomas  Clearly,  trans.  1987) ,  pp.  118-21;  Li
    Tongxuan, Entry  into  the  Realm  of  Reality,  The
    Guide: A Commentary  on  the  Gandavyuha, The  Final
    Book of the Avatamsaka Sutra (1989), pp. 45-46.

        59.   Today  deterrence   is  recognized   as  a
    legitimate  consideration   in  the  disposition  of
    convicted  defendants.  See, e.g., Haw.  Rev.  Stat.
    Ann. $ 706-606(2)(b) (Michie 1994).

        60.  For example, this is one way of approaching
    Justice Blackmun's views on the death penalty in his
    rather personal  dissent in Callins  v.  Collins, --
    U.S.  --, 114 S.  Ct.  1127, 127 L.  Ed.  2d 435, 62
    U.S.L.W. 3546 (1994).  See also, William J. Brennan,
    Jr., "Foreword: Neither  Victims  nor Executioners,"
    Notre Dame J.L.  Ethics & Pub. Pol'y.  (1994), p. 1.
    It is noteworthy  that  Justice  Blackmun  has  been
    described as being compassionate. Harold H.  Koh, "A
    Tribute to Justice Blackmun,"

                            P.281

    graphically.  The story  revolves  around  the young
    prince  and  only  child  of  King  Kasiraja   named
    Temiya-kumaro, or simply Temiya.

        Temiya is an extremely sensitive child.  One day
    when he is only a month  old he is playing  with his
    father, the King.  The King is then  called  upon to
    judge four robbers.  The King sentences the first to
    be  whipped  a  thousand  times, the  second  to  be
    imprisoned  in chains, the third  to be killed  by a
    spear, and the fourth to be impaled. Overcome by the
    karmic  consequences  of his  father's  actions  and
    fearing  what would become of him if he did the same
    after succeeding  to the throne, Temiya  refuses  to
    speak or otherwise  act like a normal  child for the
    next sixteen years.

        Finally, Temiya solves his dilemma by becoming a
    recluse(62) and converting  the royal household  and
    many others.  This story parallels the life story of
    the historical  Buddha  who grew up in a palace, but
    renounced  the  world  in  order  to seek  spiritual
    truth.

    G. Angulimala-sutta(63)

        The final  text  under  examination  is a famous
    sutra dealing  with the power of rehabilitation.(64)
    The  text  is known  as the Angulimala-sutta  or the
    "Discourse with Angulimala."(65) It is a part of the
    ------------

    Harv. L. Rev. (1994), pp. 20, 21-22. For a decidedly
    different view, see Mumia Abu-Jamal, Live from Death
    Row (1995), pp. 112-15.

        61. The Jataka or Stories of the Buddha's Former
    Births, Vol.  6, Bk.  22, pp.1-19
    For  a  look  at  the influence  of  this  jataka
    on certain  traditional legal texts in Southeast
    Asia, see "Sanction  in the Theravada Buddhist
    Kingdoms of S.E. Asia," p. 345.

        62.   As  an  interesting  aside,  there  was  a
    Temiya-like  character  in  early  twentieth-century
    Korea.  A Korean, who was working as a judge for the
    Japanese  colonial  regime in Korea (1910-1945), had
    to hand down a death  sentence.  He was so disturbed
    by what he had done that  he simply  disappeared  by
    heading  for the countryside, where  he lived  for a
    while as a peddler before becoming a Buddhist  monk.
    Eventually, the ex-judge  became  a Zen master  with
    the Buddhist name of Hyobong (1888-1966).  Robert E.
    Buswell, Jr., The Zen Monastic  Experience: Buddhist
    Practice in Contemporary Korea (1992), pp. 91-92; Mu
    Soeng (Sunum), Thousand Peaks: Korean Zen, Tradition
    and Teachers (1991), pp.  197-98. Hyobong's writings
    and life are more fully covered  in Hyobong, Hyobong
    Orok [The Analects of Hyobong] (1975) [In Korean].

        63.  The  word  sutta  in the title  is the Pali
    equivalent  of the Sanskrit sutra.  The Encyclopedia
    of Eastern Philosophy and Religion, pp. 342-43.

        64.   Rehabilitation   is  not  a  popular  idea
    politically at the moment.  See Mark Curriden, "Hard
    Time," 81 A.B.A.  J.  (July 1995), p.  72.

        65. The translation which the author has used is
    2  The  Collection  of  the  Middle  Length  Sayings
    (Majjhima-Nikaya) (Isaline B. Horner, trans.  1957),
    pp. 284-92. See also, Hellmuth Hecker, Angulimala: A
    Murder's  Road to Sainthood  (The Wheel  Publication
    No. 312, 1984).

                            P.282


    Majjhima-nikaya, or Medium Length Discourses, of the
    Fali Canon.

        Here the reader  meets a much-feared  robber and
    murderer   by  the  name   of  Angulimala(66)  which
    literally  means "Garland of Fingers."  The namesake
    garland  was said to have  been  made  by using  the
    fingers of his victims.

        Understandably, the  locals  are all  afraid  of
    Angulimala.  Nonetheless, the Buddha, who is staying
    in the area  at the time, insists  on heading  alone
    down  the road where  Angulimala  is believed  to be
    hiding.  Through  his  unique  persona,  the  Buddha
    manages  to convert  Angulimala  and ordain him as a
    monk.(67)

        Meanwhile, the King, urged  by the public, heads
    out  with   large   entourage   to  find   the  evil
    Angulimala.  He comes across the Buddha and explains
    his  situation.   The  Buddha  then  shows  him  the
    reformed Angulimala living peacefully as a monk. The
    King is quite  taken back by all this.  He is amazed
    at how the Buddha  was  able  to change  Angulimala.
    This points to a Buddhist  notion of rehabilitation.
    Naturally, rehabilitation and capital punishment are
    mutually exclusive concepts.

        Nevertheless,   in   strictly    moral    terms,
    Angulimala still had previously created considerable
    bad  karma, and he would  eventually  die a painful,
    accidental    death    because    of   this.    Yet,
    rehabilitation  is clearly  the main  theme  of this
    text.(68)

        Rehabilitation  enables  the convicted  criminal
    defendant  to realize  his  or her  mistakes  and to
    attempt  to avoid  them  in the future.  In Buddhist
    terms, a rehabilitated  offender, even  a  murderer,
    will remember his or her Buddha-nature. For society,
    reforming a wrongdoer  means regaining  a productive
    member  who can  somehow  contribute  to the general
    welfare.

                  III.   BUDDHIST RULERS

        In  the  history  of Asia  certain  rulers  have
    eagerly  embraced  Buddhism.  Many other rulers were
    Buddhist with a somewhat lesser
    ------------------

        66.  The  Sanskrit  spelling  of  this  name  is
    Angulimalya.   William  Edward  Soothill  and  Lewis
    Hodous, A Dictionary of Chinese Buddhist Terms: With
    Sanskrit and English Equivalents and a Sanskrit-Pali
    Index (1975) (1937), pp. 184, 302, 331, 454.

        67.  The tale of a latter-day  Angulimala in the
    United Kingdom is told in R.  V.  Skelton, The Times
    (London) May 18, 1983, [1983]  Grim.  L.R.  686, No.
    269/A/ 83.  Mr.  Skelton, who had been convicted  of
    larceny and burglary  several times, appears to have
    been  equal  to the task.  See Michael  Skelton, "An
    Official Meeting with a Most Remarkable Man," 58 The
    Middle Way (August 1983), pp. 99-100.

        68.  Although not as related to jurisprudence, a
    similar  story featuring  Angulimala  and the Buddha
    set  in  a  previous   life  can  be  found  in  the
    Maha-Sutasoma-Jataka.  For  a  translation, see  The
    Jataka  or Stories  of the Buddha's  Former  Births,
    Vol. 5, Bk. 21, pp. 246-79.

                            P.283


    degree of interest  in the religion.  As a result of
    their religion, some Buddhist  rulers  did away with
    the  death  penalty, while  some  did  not.  In  the
    subsections  that follow, the author has selected  a
    few representative  examples  of Buddhist  political
    leaders who had little use for the death penalty.

    A. ASOKA

        In discussing famous Buddhist political leaders,
    it is difficult  to avoid making  some reference  to
    the  Indian  Emperor  Asoka  (269? -232?  B.C.).(69)
    Asoka, also  spelled  Ashoka, ruled  an empire  that
    controlled  a  large  portion  of  South  Asia.   He
    actively promoted Buddhism throughout his empire and
    beyond.

        Despite his fondness for the ideal of ahimsa and
    his apparent  dislike  of capital  punishment, Asoka
    might  (or  might  not)  have  retained   the  death
    penalty,  and   thus   he  possibly   allowed   some
    executions to take place.  This has been a matter of
    some debate.(70)

    B. SOME OTHER SOUTH ASIAN RULERS

        An early Chinese pilgrim  to India,(71) the monk
    Fa-hsien  (337?-422?),(72) writes of an abolitionist
    Buddhist king:
    --------------

        69. See, Romila Thapar, Asoka and the Decline of
    the Mauryas (1961); Stephen Batchelor, The Awakening
    of  the West: The Encounter  of Buddhism and Western
    Culture  (1994), pp.  3-15;  Radha  Kumud  Mookerji,
    Asoka  (1962) ;   Fritz  Kern,  Asoka:  Kaiser   und
    Missionar (Willibald Kirfel, ed. 1956).

        70.  Sources  holding  that Asoka  retained  the
    death penalty include  Asoka and the Decline  of the
    Mauryas, pp.  79, 105, 176, and 202; R.G. Chaturvedi
    and  M.S.  Chaturvedi, Theory  and  Law  of  Capital
    Punishment (1989), pp. 4-5. For an alternative view,
    see  K.R.  Norman, "Asoka  and  Capital  Punishment:
    Notes on a Portion  of Asoka's  Fourth Pillar Edict,
    with   an  Appendix   on  the  Accusative   Absolute
    Construction," J.  of the  Royal  Asiatic  Soc'y  of
    Great Britain and Ireland (1975), p. 16.

        71.  Much  of what  we  know  of ancient  Indian
    history comes from external sources notably, Chinese
    and   Creek    writers.    For   whatever    reason,
    historiography  was less highly  developed  in India
    than writing on topics like philosophy and religion.
    Of  course,  by  relying   on  the  works   of  such
    non-Indians  one does need to be concerned about the
    varying  linguistic   abilities  and  the  uncertain
    extent  of local  cultural  and political  knowledge
    possessed by these foreign observers.

        Moreover, an  idealization  of  India  may  have
    occasionally   influenced  the  writing  of  Chinese
    Buddhists.   This  could   mean  that  some  Chinese
    Buddhist  pilgrims  exaggerated  the various bans on
    killing. See, e.g., D. Devahuti, Harsha: A Political
    Study (1983), p. 208.  Harsha, or Harsa, was a North
    Indian emperor (r.  606-647) who is normally thought
    of as being a great Buddhist  ruler much like Asoka.
    Nevertheless, at least one contemporary  scholar has
    maintained  that  Harsha  was really  a Hindu.  S.R.
    Goyal, Harsha and Buddhism (1986).

        In any event, in view of the fact  that a number
    of Chinese pilgrims, over a

                            P.284


          The  king  [of  Mid-India]   governs   without
          decapitation    [i.e.,   capital    punishment
          generally]  or  (other) corporal  punishments.
          Criminals   are  simply   fined,  lightly   or
          heavily, according  to the  circumstances  (of
          each case). Even in cases of repeated attempts
          at wicked rebellion  [i.e., treason],(73) they
          only have their right hands cut off....

            Throughout  the  country  the people  do not
          kill   any   living    creature,   nor   drink
          intoxicating   liquor,  nor  eat   onions   or
          garlic.(74)

        The lack of a death  penalty  here is noteworthy
    when it is recalled that pre-modern  societies often
    executed  people for a wide variety of offenses.(75)
    Indeed, Mid-India  holds  up  rather  well  even  by
    today's standards, let alone those of many centuries
    ago.

        Hye  Ch'o,(76) an  eighth-century  Korean  monk,
    made a pilgrimage  to India  similar  to Fa-hsien's,
    yet about  three centuries  later.  He too describes
    Buddhist  kings  in central  India  who rule without
    resort  to the death penalty: "The national  laws of
    the  five  regions  of India  prescribe  no  cangue,
    beatings  or prison.  Those who are guilty are fined
    in  accordance   with  the  degree  of  the  offence
    committed. There is no capital punishment."(77)
    --------------

    significant period of time, wrote of bans on killing
    and  capital  punishment, it  is  probably  safe  to
    conclude that there were at least a few abolitionist
    kings  in  ancient  India.  Finally, there  is  also
    evidence   that   there   may  have   been   several
    abolitionist  kings in parts  of medieval  Southeast
    Asia.  "Sanction  in the Theravada Buddhist Kingdoms
    of S.E. Asia," p. 346.

        72. The author has relied mostly on James Legge,
    trans., "A  Record  of Buddhist  Kingdoms: Being  an
    Account  by the Chinese  Monk Fa-Hieh of his Travels
    in India and Ceylon  (A.D.  399-414)," in Search  of
    the Buddhist Books of Discipline (1965) (1886).  The
    author  has also consulted  A Record of the Buddhist
    Countries (Li Yunghst, trans.  1957); The Pilgrimage
    of  Fa  Hian  [sic]  Remusat  et  al, trans.  1848);
    Travels  of Fah-Hian  [sic]  and Sung  Yun, Buddhist
    Pilgrims from China to India (400 A.D. and 518 A.D.)
    (Samuel  Beal,  trans.   1964)  (1869) .   See  also
    Si-Yu-ki: Buddhist  Records  of the Western World --
    Translated  from the Chinese  of Hiuen  tsian  (A.D.
    629) (Samuel Beal, trans. 1969) (1884).

        73. Treason is often treated as the most serious
    of all crimes.  In the United  Kingdom, for example,
    treason  remains a capital  offense  while murder is
    not. A Concise Dictionary of Law, (20 ed. 1990), pp.
    54-55, 420; Capital Punishment [1970] Crim. L.R. 65.

        74.  A Record  of  Buddhist  Kingdoms: Being  an
    Account  by the Chinese  Monk Fa-Hieh of His Travels
    in India and Ceylon, p. 43.

        75.  See, e.g., Ramaprasad  Das Gupta, Crime and
    Punishment  in Ancient  India  (1930);  Lawrence  M.
    Friedman, Crime and Punishment  in American  History
    (1993); Richard van Dulmen, Theatre of Horror: Crime
    and Punishment  in Early Modern  Germany  (Elisabeth
    Neu,  trans.  1990);  J.M.  Beattie, Crime  and  the
    Courts in England 1660-1800 (1986).

        76.  Some older Western works on Hye Ch'o have
    the Chinese  characters  in his name  transliterated
    according  to a Chinese  pronunciation  such as "Hui
    Ch'ao" instead of according  to the standard  Korean
    pronunciation  of "Hye Ch'o."

        77.  Hye Ch'o, The Hye Ch'o Diary: Memoir of the
    Pilgrimage  to  the  Five  Regions  of  India  (Yang
    Han-Sung et al, trans. and ed. 1980) pp. 40-41.


                            P.285


        Hye Ch'o found an almost identical  situation in
    West  India: "Here  there  is  no  cangue,  beating,
    prison,    capital     punishment,    and    similar
    affairs."(78)

        A similar situation  in another  ancient land is
    described by the sixth-century Chinese pilgrims Sung
    Yun and Hui Sheng:

          [W]e entered Ouchang country (Oudyana). On the
          north this country  borders  on the Tsung Ling
          mountains;  on the south  it skirts  India....
          The king of the country religiously observes a
          vegetable  diet....  After mid-day  he devotes
          himself   to  the   affairs   of   government.
          Supposing  a man has committed murder, they do
          not suffer  him to be killed, they only banish
          him  to the  desert  mountains, affording  him
          just food enough to keep him alive (lit. a bit
          and a sup).  [In doubtful  legal cases]  after
          examination,  the   punishment   is   adjusted
          according  to the serious or trivial character
          of attending circumstances.(79)

        Earlier  we met King  Udayi, the person  to whom
    Nagarjuna addressed his treatise.

        As is all  too often  the case  with  pre-modern
    Indian  history, there is precious  little  detailed
    information on the nature of King Udayi's reign, but
    it  does  appear   to  have  been   a  gentle   one.
    Presumably, Nagarjuna's  advice  was  not completely
    ignored.(80)

    C. EARLY JAPANESE EMPERORS

        Pre-modern Japanese governments were often harsh
    on prisoners.(81) Even today Japan retains the death
    penalty.(82) Yet, there  was a time when  Japan  did
    not have  the death  penalty.(83) In 724 AD, Emperor
    Shomu (r.  724-749), a devout Buddhist  and follower
    of the Kegon
    --------
        78. Ibid., p. 44.

        79.  Travels of Fah-Hian  and Sung Yun, Buddhist
    Pilgrims  from  China  to India  (400  A.D.  and 518
    A.D.), pp. 188-89.

        80.  "Nagarjuna's Guidelines for Buddhist Social
    Action," p. 129.

        81.   John  Carey  Hall,  Japanese   Feudal  Law
    (Studies  in  Japanese  Law  and  Government) (1979)
    (1906).

        82.  Amnesty International, The Death Penalty in
    Japan: Report of an International  Mission to Japan,
    21  February-3  March  1983  (1983),  p.  2;  Koichi
    Kikuta, "The Death Penalty  in Japan: Why Hasn't  It
    Been Abolished?" 1 Meiji L.J. (1994), p. 43.

        83.   It  has  been  argued   that  a  hoped-for
    elimination  of the death penalty  in Japan is fully
    consistent  with the teachings of Japanese Buddhism.
    John  M.  Peek,  "Buddhism,  Human  Rights  and  the
    Japanese State," 17 Hum. Rts. Q.  (1995), p. 527. It
    is also worth noting that when Amnesty International
    visited  Japan  in  1983, the  only  major  Japanese
    political  party that had gone on record as opposing
    the  death  penalty  was  the  Komieto, a  generally
    conservative   party  with  strong  ties  to  a  lay
    Buddhist  movement  named  Soka  Gakkai.  The  Death
    Penalty in Japan: Report of an International Mission
    to Japan, p. 17.

                            P.286


    School  who  built  Todai-ji, a famous  temple  that
    still stands  in Nara, forbade  the use of the death
    penalty.  This was during the end of the Nara Period
    (715-794).  Likewise, there were very few executions
    during the Heian Period (794-1185).(84)

    D. DALAI LAMA XIII

        Thubten   Gyatso,  Dalai   Lama  XIII  of  Tibet
    (1876-1933), was  the  predecessor  of  the  current
    Dalai Lama i.e., Tenzin Gyatso, Dalai Lama XIV (born
    1935) .  The  Thirteenth  Dalai  Lama  struggled  to
    modernize   Tibet  and  to  maintain  the  country's
    sovereignty   against  the  British  and  later  the
    Chinese.  He  also  reformed  Tibet's  feudal  legal
    system.  Among the changes was the abolition  of the
    death penalty  by about 1920.  Before  that time the
    Dalai  Lama would avoid  any direct  involvement  in
    cases of capital punishment because of his religious
    role.(85)

    IV.   CAPITAL   PUNISHMENT   AND  HUMAN  RIGHTS   IN
                OFFICIALLY BUDDHIST NATIONS

        Although in pre-modern times Buddhism managed to
    spread  throughout  virtually  all of Asia,(86) most
    Asian  countries  with  large  Buddhist  populations
    today  have  secular  governments.  Nevertheless, in
    contemporary  Asia there are four nations  that have
    Buddhism    as   the   state   religion.(87)   These
    nations(88) are: Bhutan, Cambodia, Sri
    ----------

        84.   Taitetsu   Unno,  "Personal   Rights   and
    Contemporary  Buddhism," in  Human  Rights  and  the
    World's Religions (Leroy S.  Rouner, ed.  1988), pp.
    129,  146;   Junjiro  Takakusu,  The  Essentials  of
    Buddhist Philosophy  (Wing-tsit  Chan and Charles A.
    Moore, eds. 1956), p. 112. Apparently, executions in
    Japan finally resumed once the fairly peaceful Heian
    Period began to give way to the great political  and
    social unrest of the Kamakura Period (1192-1336).  A
    History  of  Japanese   Buddhism,  pp.   68-70.   In
    particular, a series of executions are known to have
    taken place in the year 1156.  These executions were
    the  outcome  of  clan  warfare.  George  Sansom,  A
    History of Japan to 1334 (1958), p. 256.

        85.  Franz Michael, Rule by Incarnation: Tibetan
    Buddhism  and Its Role in Society  and State (1982),
    pp.  70, 109.  For  a  glimpse  of  the  traditional
    Tibetan criminal justice system, see Rebecca Redwood
    French, The  Golden  Yoke: The  Legal  Cosmology  of
    Buddhist Tibet (1995), pp. 315-25.

        86.  See, e.g., Kenneth  K.  Inada, "A  Buddhist
    Response  to the Nature  of Human  Rights," in Asian
    Perspectives  on Human Rights (Claude E.  Welch, Jr.
    and Virginia A. Leary eds., 1990), p. 91.

        87.  For this section  the author  has generally
    drawn  upon  the  following   sources:  Letter  from
    Amnesty International (London) to Damien P.  Horigan
    (Sept.  19, 1995) (on  file  with  author);  Barbara
    Crossette,  So  Close   to  Heaven:  The   Vanishing
    Buddhist Kingdoms of the Himalayas  (1995), p.  178;
    Adrian Karatnycky  et al, Freedom  in the World: The
    Annual Survey of Political  Rights & Civil Liberties
    1994-1995 (1995);


                            P.287


    Lanka,(89) and Thailand.  Bhutan, which lacks a true
    written  constitution,  follows  Mahayana  or,  more
    accurately, Vajrayana  Buddhism, whereas  the  other
    three  all follow  Theravada  Buddhism.  Of the four
    nations, only  Sri Lanka  has a republican  form  of
    government.  The  remaining  three  are all kingdoms
    with varying degrees of popular representation.  How
    do  modern  governments  that  claim  some  official
    connection  with  Buddhism  approach  the  issue  of
    capital punishment?(90)

        Currently, of the  four  nations, only  Cambodia
    has  clearly  eliminated  the  death  penalty.  This
    recent  reform has been enshrined  in Article  32 of
    The  Constitution   of  the   Kingdom   of  Cambodia
    (1993).(91)

        Capital  punishment  remains  on  the  books  in
    Bhutan and Thailand alike.  However, both King Jigme
    Singye Wanchuk of Bhutan and King Bhumibol Alduyadej
    (Rama IX) of Thailand  have been following  a policy
    of commuting  death sentences.  Apparently, official
    executions  have not taken  place in either  country
    for  a  number   of  years.   This   is  a  welcomed
    development.  Hopefully, the  governments  of Bhutan
    and Thailand  will each  see fit to formally  outlaw
    capital   punishment   in   the   near   future.(92)
    ----------

    Constitutions of the Countries of the World (Gisbert
    H.  Flanz, ed.  1995);  The Far East and Australasia
    1995;  Terence  Duffy, "Toward  a Culture  of  Human
    Rights  in  Cambodia," 16 Hum.  Rts.  Q.  82 (1994);
    Humana,  supra  note  1,  passim;   Edward   Lawson,
    Encyclopedia of Numan Rights (1991); Roger Hood, The
    Death Penalty: A World-Wide Perspective, A Report to
    the United Nations Committee on Crime Prevention and
    Control (1990);  Buddhist  Trends in Southeast  Asia
    (Trevor Ling, ed. 1993).

        88.  For the purposes of this section, the Dalai
    Lama's  Tibetan   government   in  exile,  based  in
    Dharamsala,  Himachal  Pradesh, India, will  not  be
    considered a nation.

        89.   Sri  Lanka  remains  officially   Buddhist
    despite some Western reports to the contrary. Letter
    from  the  Embassy   of  the  Democratic   Socialist
    Republic  of Sri Lanka  (Washington, D.C.) to Damien
    P.  Horigan  (Oct.  30, 1995) (on file with author).
    Some  of the confusion  in this  area arises  due to
    what exactly  is meant by the term "state religion."
    Although     other    religions     are    protected
    constitutionally, Buddhism  is specially  recognized
    in the Sri Lankan Constitution.  Chapter II, Section
    9  of  the  Sri  Lankan  Constitution   reads:  "The
    Republic  of Sri Lanka [sic] shall give Buddhism the
    foremost place and accordingly  it shall be the duty
    of the State to protect and foster the Buddha Sasana
    [Buddhism], while  assuring  to  all  religions  the
    rights  granted  by  Articles  10  and  14(1) (e) ."
    Constitutions  of the Countries of the World, Binder
    XVIII.

        90. Virtually every nation in Asia has a serious
    human rights problem.  Extrajudicial killings, civil
    wars, torture, and censorship  are tragic  realities
    of the region.  For  the purposes  of this  article,
    however,  the  author  will  concentrate   on  legal
    killings.

        91. For an English version of this constitution,
    see  Constitutions  of the Countries  of the  World,
    Binder III.

        92.  Thailand  could amend its constitution.  In
    Bhutan this could presumably be carried out by means
    of some sort of royal decree.

                            P.288


        Sri Lanka  stands  out as the most disappointing
    of the  four.  The Sri  Lankan  government  actually
    appears  to  be  moving  toward  increasing  use  of
    executions."  As  it should  be clear  by  now, such
    practice is hard to justify from a Buddhist point of
    view.   If  the  Sri  Lankan  government  takes  its
    Buddhism  seriously, then  it should, at very least,
    reduce  the  number  of  executions   being  carried
    out.(94)

                          V. CONCLUSION

        An  abolitionist  stance  on capital  punishment
    finds  strong  support   in  Buddhist   thought  and
    history.  Compassion  fosters a deep respect for the
    dignity of all forms of life. The lives of convicted
    criminal defendants do have value.

        Society   should  strive  to  rehabilitate   all
    prisoners to enable them to awaken to their inherent
    potential for goodness and spiritual growth. Capital
    punishment   is  anathema  to  rehabilitation.   One
    obviously   cannot   rehabilitate   a  dead  inmate.
    Furthermore, retribution, which  would  arguably  be
    the  strongest   reason  for  retaining   the  death
    penalty, is not in keeping  with  the  compassionate
    spirit of Buddhism.

        That Buddhism  should speak out against  capital
    punishment  is significant  because  Buddhism  is  a
    world religion in its own right.  Buddhism has had a
    profound impact on the major civilizations  of Asia.
    Moreover,  Buddhism  enjoys  a  modest  yet  growing
    presence in the United States and elsewhere  outside
    of   Asia.(95)   Finally,   an   American   Buddhist
    perspective on the death penalty can help inform the
    ongoing debate surrounding  capital punishment among
    Americans, much  as Gandhian  ahimsa  has positively
    influenced some Christians and non-Christians in the
    United  States  to strive  for  racial  harmony  and
    social justice.
    ----------

        93.  See, e.g., "Hard  Core  Criminals  will  be
    Hanged," Sri Lanka  Express  (Arleta, CA), July  14,
    1995, p.  3.  For  a general  history  of  political
    violence in Sri Lanka, see Stanley Jeyaraja Tambiah,
    Buddhism Betrayed?: Religion, Politics, and Violence
    in Sri Lanka (1992).

        94.  Some  Sri Lankan  Buddhists  have  gone  on
    record as opposing capital punishment. See Sri Lanka
    Foundation, Human Rights and Religions in Sri Lanka:
    A Commentary  on the Universal Declaration  of Human
    Rights (1988), p. 23.

        95.  See  generally, The Awakening  of the West:
    The Encounter  of Buddhism  and Western  Culture, p.
    69.