The Case of Paanchi

The Case of Paanchi

In the beginning of the 40th year of the reign of the judges, chief judge Pahoran died, initiating a succession crisis as three of his sons—Pahoran, Pacumeni, and Paanchi—contended for the judgment seat (Helaman 1:1–3). Of the three brothers, the people ended up choosing Pahoran as the next chief judge, after which Pacumeni united with the voice the people (vv. 5–6). However, Paanchi was

exceedingly wroth; therefore, he was about to flatter away those people to rise up in rebellion against their brethren. And it came to pass as he was about to do this, behold, he was taken, and was tried according to the voice of the people, and condemned unto death; for he had raised up in rebellion and sought to destroy the liberty of the people. (Helaman 1:7–8)

While it might seem insignificant at first glance, the fact that Paanchi was merely “about to” incite a rebellion may be crucial to the telling of this legal incident. Participation in a conspiracy to incite rebellion would almost certainly have been viewed as a capital offense in ancient Israel and in the early years of the Nephite monarchy (as it was in other ancient societies at the time), but Mosiah’s legal reforms may have complicated this legal issue.¹ 

 

As explained by legal scholar John W. Welch,

In particular, under the law inaugurated by King Mosiah, it had become clear that a person could not be punished for his thoughts or beliefs alone (Alma 1:17; 30:7). That principle would seem to make it impossible for a judge in Zarahemla to convict a person merely on the basis of belief or intent alone. At least this question (and related ones) may well have arisen in some minds: Had the law of Mosiah modified in any way the old law regarding conspiracy or incitement? How much aid, help, or action needed to be involved in the case before the inciter could be executed? Did an actual rebellion need to begin, or was it enough (as in Paanchi’s case) for the accused to have been on the very cusp of calling for armed rebellion?²

Evidence that this wasn’t a settled matter may be seen in the fact that instead of Pahoran, as the newly elected chief judge, passing a sentence on Paanchi, he was instead “tried according to the voice of the people” (Heleman 1:8). If Pahoran had unilaterally sentenced his brother to death, “certain factions in the society might have claimed that he had acted out of self-interest or that he lacked jurisdiction in the matter.”³

This issue could have been further complicated by the fact that Pahoran’s status as the chief judge was the very thing being debated by the different parties. As Welch described it, “there may have been some potential argument that no chief judge had yet been definitively and authoritatively installed; and accordingly, in the case of such a contested appointment, jurisdiction and legal authority would have reverted back to the voice of the people in their basic political groups.”⁴

Literary Significance

Unlike other legal incidents in the Book of Mormon, the case of Paanchi is briefly told and therefore sparse on details that might connect it further to biblical or Near Eastern legal customs. However, contextualizing this case in light of the surrounding historical events can help shed light on its literary significance and legal legacy. Welch argued,

In all societies, the crimes of conspiracy and incitement are difficult to define and even harder to enforce. Given the serious difficulties that the Nephites experienced as a result of the secret combinations of the Gadianton robbers in the fifty years preceding the appearance of Christ, this legal concept likely became a key point in Nephite law during the years covered by the book of Helaman and the first few chapters of 3 Nephi. Perhaps for this reason, among others, the writers and abridgers of the book of Helaman positioned the case of Paanchi at the very outset of that book. As the leading motif of the book of Helaman, this legal issue confronts readers over and over during this period of Nephite history. … Out of the sedition of Paanchi grew the principal Nephite precedent that legally defined conspiracy.⁵

In his final analysis, Welch concluded,

Thus the outcomes and repercussions of the trial of Paanchi, which must have been perceived as unjust in the minds of Paanchi’s followers and others who would have felt threatened by the precedent set by this case, surely contributed to other conditions that were plentiful in Nephite society in the middle of the first century BC that incubated the rise of the militant Gadianton robbers and the other bands of social brigands that became such a sore curse among the Nephites for the next seventy-five years.⁶

Conclusion

The political circumstances leading up to this legal incident are fitting. A mere passing glance at the histories of many nations reveals that power squabbles, including among rival heirs, often come to a head during times of political transition. The terrible aftermath of Paanchi’s execution is also understandable, and helps explain why this event was recorded in the first place. Paanchi’s followers soon sent Kishkumen to assassinate Pahoran (Helaman 1:9–12), which conspiracy became the prototype for subsequent groups of dissidents and bandits (Helaman 2:12–14). Thus, Mormon’s inclusion of this narrative at the beginning of the book of Helaman makes good literary sense.

While sparse in detail, the case of Paanchi is also plausible on legal grounds. Even though the account’s precise legal issues aren’t clearly spelled out for the reader, textual clues hint at an underlying legal uncertainty and tension in the wake of Mosiah’s reforms. As concluded by Welch,

… the case of Paanchi and the deaths of Pahoran and Pacumeni served to establish the continuing legal right of the people to regulate their important judicial affairs “by the voice of the people.” This case, which stands as a prologue to the book of Helaman, establishes the clear illegality of the very kinds of secret activities that continuously plagued the Nephites throughout the book of Helaman and into the first parts of 3 Nephi.⁷

John W. Welch, The Legal Cases in the Book of Mormon (Provo, UT: BYU Press, 2008), 311–322.

Helaman 1:1–13

Helaman 1:1–13