12 Angry Men – The Concept of Hard-Case

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Plot Summary

One fine morning, 12 men were called to sit in a jury to serve their duty of imparting their perspective over a murder trial. Accused in on trial for first degree murder of his abusive father. Since, the setting of film is based according to rules and norms of 1950s, which means if defendant is convicted, he’ll receive death sentence by electric chair.  There were conflicting opinions among the jurors, they were divided on whether the defendant is guilty or not. Most of them formed opinion against defendant, though the opinions were driven by the events happened in personal life of jurors. In order to form unambiguous decision, Juror 12 suggested to present the reasons behind verdicts of each juror as a method of convincing all.

Eventually by the way of logic-based reasons, jurors switched their vote. Initially, it seemed the defendant will be getting a chair but Juror eight’s arguments convinced rest of the jurors.

Justice & Morality

12 Angry Men, this film is about how the justice system is supposed to work in the welfare of society and why the judges should not be subjective in providing a decision as it is harmful and non-acceptable for maintaining social harmony (implied in the movie), before further explanation let us see how the justice system is derived and its relation with morality. The very first principle enshrined under natural law is “Good to be done and pursued and evil to be avoided”. Historically, natural law refers to the use of reason to analyse human nature in order to bind rules of moral behaviour. Our whole theory of jurisprudence, our Constitution, is based on “natural law” & “How the world ought to be and how people ought to behave”, these two sentences connects the concept of Morality and Justice. Morality is universal in nature and justice system on the other hand may vary from place to place. Even though justice varies in territories but justice is derived from the morality that exists in the mind of most rational citizen of society. Justice is about providing or serving people with their rights, it’s a set of rules which control the social behaviour of people while morality is related to concept of good and bad. Point to notice is that moral views are contradictory from person to person or culture to culture. So, when your personal conception of morality is not socially acceptable, you may end up facing justice system.

Ronal Dworkin, Interpretivism & Hard-Case

Interpretivists claim law has a relationship with ethics and morality. Ronald Dworkin (an american philosopher, jurist, and scholar of United States constitutional law) is often associated with Interpretivism. Interpretivism is a school of thought in modern jurisprudence and the philosophy of law. In a hard case, there are inconsistent paths of interpreting the law, and thus what the result should be. An instance of a hard case as suggested by Ronald Dworkin, is Riggs v. Palmer.[i] In this case, Palmer left significant part of his property and asset in his will to his grandson and relatively lesser amount to his two daughters. His grandson Elmer Palmer feared that the will could be altered and in order to prevent any alteration in will, he killed his grandfather by poison. Although, Elmer Palmer was put on stand for crime of murder but there was no provision whatsoever available to prevent Elmer Palmer to claim inheritance. Plaintiff in the case argued if the inheritance is transferred to defendant then it would mean that Elmer Palmer is profiting from his crime, which is contradictory to the morals of society and, ultimately against the purpose of law. Court ruled in the favour of plaintiff – “by the reason of crime committed by Elmer Palmer upon his grandfather, Elmer was deprived of any interest left by the testator as he could not vest himself with title by crime.

In the above case it was decided what society thinks is just, similarly in the movie 12 Angry men sentencing a person to death without looking at the reasonable doubts is against the society norms. With interpretivism, as promoted by Dworkin, a ‘right’ verdict can be reached to settle hard cases by rendering the sources so that a result becomes clear.

Right Thesis

Dworkin’s Right Thesis includes the general statement that under the ambit of legal exercise and an appropriate understanding of the nature of law, rights are more fundamental than rules. Different judge may come to different assumptions but Dworkin holds that judges should not rely on their own political understandings but only on their beliefs in the accuracy of those verdicts. In the context of the movie 12 Angry Men, the movie started and every one of the jurors is convinced that the boy on trial is guilty because of their personal prejudice and grudge against their own personal kids (in the case of juror #3). Without looking at the reasonable doubt they all were ready to serve him to the chair (it’s a method of executing a person in old time). Dworkin believes that in every hard case, there is a precise decision (right answer) which accurately evaluates values or principles, protects natural rights and is steady with the society’s morals. In hard cases, the decision is uncertain or random. This occur when:

  1. The lawyers would not agree upon the rights of the individual
  2. When there is no settled rule to elect the case or the application of the settled rule would be such that it would leave to an outcome which is not suitable.

Dworkin argues that if a sceptic person argues that there is no correct answer, it is similar to substantive moral claims (claims based on one’s beliefs).[ii] There is right answer in hard cases, hidden behind reasoning.


As I discussed Natural law concerns with morality and judgement capability inherent in human nature. In the film it was seen that 12 people were being called to sit on a jury of 1st degree murder trial. 11 out of 12 jurors are convinced that the defendant is guilty but 1 of the jurors used his simple reasoning skills to find out if the boy is really guilty, he was just not ready to sentence a man to death without having a proper look at the evidences & testimonies of eye witnesses. This film explains how people’s personal prejudice and biasness affects outcome of any trial. Ronald Dworkin in his work (RIGHT THESIS) said different judges may come to different conclusions based on their own political and personal affairs but he insists that judges should focus on soundness of those convictions. Natural law theory imitates a perpetual quest for absolute justice.

In the climax of film, the arguments based on reasonable doubts of juror #8 finally convinced all the others that the defendant is not guilty. Thus, doesn’t deserve sentence to death by chair.

[i] Riggs V Palmer [1889], 115 N.Y. 506 [1889]

[ii] Teoh Wen, “DWORKIN – right answer and hard cases”, academia.edu, Available at – https://www.academia.edu/4270113/4DWORKIN_right_answer_and_hard_cases (Accessed on – 10 June 2021)

Written By

Mrinal Datiwal

Rajiv Gandhi National University of Law, Punjab

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