In death penalty cases, the Supreme Court applies the 'rarest of rare' doctrine and requires consideration of aggravating/mitigating circumstances. Which factor is NOT typically considered a mitigating circumstance?

Death penalty and mitigating circumstances: (a) 'Rarest of rare' doctrine (Bachan Singh, 1980): Death penalty only in rarest of rare cases where alternative is unquestionably foreclosed, (b) Aggravating circumstances: (i) Heinous nature of crime with premeditation, (ii) Extreme brutality, (iii) Victim vulnerability (child, woman, disabled), (iv) Prior criminal record, (c) Mitigating circumstances: (i) Young age of accused, mental illness, intellectual disability, (ii) Possibility of reformation, rehabilitation, (iii) Socio-economic background, provocation, (iv) Cooperation with investigation, remorse, (d) Procedural safeguards: (i) Separate sentencing hearing: Aggravating/mitigating factors considered after conviction, (ii) Reasoned order: Court must record reasons for imposing/commuting death penalty, (iii) Appellate review: Automatic appeal to High Court, Supreme Court for death sentences, (e) Applications: (i) Commutation: Courts commute death penalty where mitigating factors outweigh aggravating, (ii) Delay in execution: Inordinate delay in execution can be ground for commutation as it violates Article 21, (iii) Mental health: Courts consider mental illness, trauma as mitigating factor, (f) Illustrates dignity-centric constitutionalism: Article 21 interpreted to require utmost caution in death penalty; proportionality ensures punishment calibrated to crime, offender, with dignity, reformation in mind.