How can evil doers be 'reborn' as 'human'?

As simple as possible but not simpler: Birth as a human means that you have accumulated good karma in the past! However nobody has ever explained the amount of karma,it's measuring unit.The moral code has always been it's meter of measure!

• Know that both heaven and hell are labyrinths for the soul.Sooner or later the soul finds its way out!

After all what you think,you become!Nothing is permanent,even those souls can change,that's why they are reborn as humans,however once a human you pay your karma,your bad luck,being poor,ignorant and so on.

• Hope for enlightenment!

I think what described here is that (it says IF), if in case that person posesses good kamma (he/she gained from previous lives or good kamma that can erase bad) enough to bring him/ her back to human state but not to hell, then he/she will have a short-lived lives.

Sometimes it happens like this also; He/she suffers in hell for a long time (too long), and when finaly he/she is done spending his/her kamma relevant to the hell state, born again as an animal. (may go to ghost world as well) then once that kamma is also spent, then goes back to human state but with short-lives; Until all kamma relevant for that mis-deed is finaly spent off.

Sorry for my english, im not a good writer in buddhism.

Human rebirth is a consequence of merit. However, every person is a complex stew of positive and negative karmas. Each subsequent rebirth is not the consequence of a single karma - it is the result of the confluence of all previous karmas, the number of which is incalculable. If one possesses sufficient karma to be reborn in a meritorious state, i.e., human rebirth, it does not follow that there no negative karmas are present, or that the human life will necessarily be free of negative karmas, the latter because human volition is essentially free, though conditioned. Thus human life, while meritorious in itself, exhibits both positive and negative aspects, and beings possessing negative karmas may be reborn as humans.

There's no conflict between MN 135 and the rest of the Suttas. From this beginningless Samsara, no body in it had not once committed some very terrible kamma at some point and some very wholesome kamma other time. Even one of the Buddha's greatest disciples, Ven. Moggallana, in a distant past life, committed the horrific kamma (one of the Five Heinous Acts) of murdering his parents. No body is able to see the exact working of kamma except the enlightened ones, but we can safely assume it'll unfold according to a certain algorithm that takes into account of all the actions an individual has done in many life times, one of which s/he might had saved many lives, and at other point, killed someone. The only exception is the Five Heinous Acts which guarantee an immediate fruit of a rebirth in hell. So basically, the moral of the story is that until attaining the rank of the Noble Ones, starting with Sotapanna, all human beings are still capable of and potentially commit great harm and great help to their fellow human beings and hence reap the appropriate results accordingly. We'll continue to ride this merry-go-round of the Six Realms of existence, sometime experiencing much suffering as a hell being, other the countless pleasures as a deva, etc.

"In the Pali suttas, SN 56.102-113 state those that realise the Four Noble Truth will be 'reborn in the human state' (manussesu paccājāyanti)."

[edit]:

Assuming we agree with Bodhi translation, let me quote it:

"So too, bhikkhus, those beings are few who, when they pass away as human beings, are reborn among human beings. But those beings are more numerous who, when they pass away as human beings, are reborn in hell. For what reason? Because, bhikkhus, they have not seen the Four Noble Truths."

I don't read that sutta stating that those who realise the Four Noble Truths will be reborn in the human state.

What I read is that the reason why so many people reappear in a bad destinations contrasting with so few who reappear in better ones is because they haven't seen the Four Noble Truths.

Furthermore, to better illustrate a subtleness of logic, consider the following statement:

"So too, those beings are few who, when trying to construct a bridge, successfully construct it. But those beings are more numerous who, when trying to construct a bridge, fail. For what reason? Because they have not obtained a PhD in civil engineering".

The above does not necessarily say that everyone who constructed a bridge (i.e. reappeared in a good destination) necessarily have a PhD in civil engineering (i.e. saw the FNT). It also does not necessarily say that all bridges constructed were constructed by a PhD in civil engineering (i.e. it does not say that all beings who reappeared in human realm saw the FNT).

In the same way, I don't read the Buddha saying that those who see the four noble truths will reappear in the human realm (as stated in the question). And just for completeness, I also don't read the Buddha saying that all those who appear in human realm necessarily saw the Four Noble Truths. In other words, and to be more precise, it does not seem to say that seeing the FNT is a necessary (or necessary and sufficient) requirement for appearing in human (or deva) realm.

Furthermore, the intent of the sutta seems to be to inspire by showing how easy is to reappear in a bad destination, and to take the opportunity to dedicate to the dhamma practice which would be the best bet to reappear in a better destination. It informs that those who see the FNT have something going for them to reappear in human realm or better destinations, like a civil engineering training is a good bet for successfully constructing bridges (but not necessarily a necessary requirement for building one).

"How can this be? How can one single sutta (Cula-Kammavibhanga Sutta) override the doctrine [...]"

It's not the case that a single sutta overrides a doctrine. A few suttas explain that kamma always comes to fruition at some point:

“Bhikkhus, I do not say that there is a termination of volitional kamma that has been done and accumulated so long as one has not experienced its results, and that may be immediately [in this very life], or soon after [in the next rebirth], or after that [on some subsequent occasion].

-- AN 10.218

Some notes on translation of the above here and and here.

MN 135 is also not a single sutta that says something to the effect of not tying deterministically the deed to the rebirth destination. The Maha-Kammavibhanga Sutta is even more emphatic, and fully explains all possibilities of rebirth:

(i) “Now, Ananda, there is the person who has killed living beings here… has had wrong view. And on the dissolution of the body, after death, he reappears in the states of deprivation, in an unhappy destination, in perdition, in hell. But (perhaps) the evil kamma producing his suffering was done by him earlier, or the evil kamma producing his suffering was done by him later, or wrong view was undertaken and completed by him at the time of his death. And that was why, on the dissolution of the body, after death, he reappeared in the states of deprivation, in an unhappy destination, in perdition, in hell. But since he has killed living beings here… has had wrong view, he will feel the result of that here and now, or in his next rebirth, or in some subsequent existence.

(ii) “Now there is the person who has killed living beings here… has had wrong view. And on the dissolution of the body, after death, he reappears in a happy destination, in the heavenly world. But (perhaps) the good kamma producing his happiness was done by him earlier, or the good kamma producing his happiness was done by him later, or right view was undertaken and completed by him at the time of his death. [...]

(iii) “Now there is the person who has abstained from killing living beings here… has had right view. And on the dissolution of the body, after death, he reappears in a happy destination, in the heavenly world. But (perhaps) the good kamma producing his happiness was done by him earlier, or the good kamma producing his happiness was done by him later, or right view was undertaken and completed by him at the time of his death. [...]

(iv) “Now there is the person who has abstained from killing living beings here… has had right view. And on the dissolution of the body, after death, he reappears in the states of deprivation, in an unhappy destination, in perdition, in hell. But (perhaps) the evil kamma producing his suffering was done by him earlier, or the evil kamma producing his suffering was done by him later, or wrong view was undertaken and completed by him at the time of his death.

-- MN 136

The idea that the nature of the result of kamma can be drawn solely based on the deed is contested in suttas such as The Salt Crystal:

“Monks, for anyone who says, ‘In whatever way a person makes kamma, that is how it is experienced,’ there is no living of the holy life, there is no opportunity for the right ending of stress. But for anyone who says, ‘When a person makes kamma to be felt in such & such a way, that is how its result is experienced,’ there is the living of the holy life, there is the opportunity for the right ending of stress.

He goes on to say:

“There is the case where a trifling evil deed done by a certain individual takes him to hell. There is the case where the very same sort of trifling deed done by another individual is experienced in the here & now, and for the most part barely appears for a moment.

“Now, a trifling evil deed done by what sort of individual takes him to hell? There is the case where a certain individual is undeveloped in [contemplating] the body, undeveloped in virtue, undeveloped in mind, undeveloped in discernment: restricted, small-hearted, dwelling with suffering. A trifling evil deed done by this sort of individual takes him to hell.

“Now, a trifling evil deed done by what sort of individual is experienced in the here & now, and for the most part barely appears for a moment? There is the case where a certain individual is developed in [contemplating] the body, developed in virtue, developed in mind, developed in discernment: unrestricted, large-hearted, dwelling with the immeasurable. A trifling evil deed done by this sort of individual is experienced in the here & now, and for the most part barely appears for a moment.

-- An 3.100

In the following passage, the Buddha refutes the idea that "Whatever this person experiences—whether pleasure, pain, or neither-pain-nor-pleasure—all that is caused by what was done in the past.":

“Bhikkhus, there are these three sectarian tenets which, when questioned, interrogated, and cross-examined by the wise, and taken to their conclusion, will eventuate in non-doing. What are the three?

(1) “There are, bhikkhus, some ascetics and brahmins who hold such a doctrine and view as this: ‘Whatever this person experiences—whether pleasure, pain, or neither-pain-nor-pleasure—all that is caused by what was done in the past.’

[...]

(1) “Bhikkhus, I approached those ascetics and brahmins who hold such a doctrine and view as this: ‘Whatever this person experiences—whether pleasure, pain, or neither-pain-nor-pleasure—all that is caused by past deeds,’ and I said to them: ‘Is it true that you venerable ones hold such a doctrine and view?’ When I ask them this, they affirm it. Then I say to them: ‘In such a case, it is due to past deeds that you might destroy life, take what is not given, indulge in sexual activity, speak falsehood, utter divisive speech, speak harshly, indulge in idle chatter; that you might be full of longing, have a mind of ill will, and hold wrong view.’

“Those who fall back on past deeds as the essential truth have no desire to do what should be done and to avoid doing what should not be done, nor do they make an effort in this respect. Since they do not apprehend as true and valid anything that should be done or should not be done, they are muddle-minded, they do not guard themselves, and even the personal designation ‘ascetic’ could not be legitimately applied to them. This was my first legitimate refutation of those ascetics and brahmins who hold such a doctrine and view.

-- AN 3.61

Moreover, some suttas (such as MN 136) give prominent role to right view at the moment of death and to whether consciousness is tied to sensual gratification at the moment of the death, things that seem to exert strong forces that influence the next destination (see the question Last thought before death?).

[edit]:

Finally, I understand that it's not that a brutal bloody-handed killer of living beings will be reborn here or there. There's no such killer: there's the killing, and there are also all other good & bad deeds performed in the past, and when these deeds come to fruition, to quote the Buddha again in AN 3.61: "When a person makes kamma to be experienced in such & such a way, that is how its result is experienced."

might be lost in translation somehow. from this

"No ce kāyassa bhedā paraṃ maraṇā apāyaṃ duggatiṃ vinipātaṃ nirayaṃ upapajjati, sace manussattaṃ ..

if replace "in stead of" with "if not" , that it makes more sense.

if not reappearing in the plane of deprivation, the bad destination, the lower realms, hell — he/she comes to the human state,....

It could also mean that when karma is exhausted in suffering plane, and being appear in human world after? So once you burn your "debt" you move to the next phase or rebirth, lacking the "debt"

The vice versa is said to occur at the end of a rebirth in the heavens as a god. They burn through their "good debt" quickly and tend to fall into the lower realms when their dues are paid.

I am an amateur self taught Pali. I could be wrong but at least it opens up for those who know more about Pali to chime in. Could "No ce" together with rest of a sentence, is better to translate to "if not" rather than "instead of"?