Supreme Court: Sessions Court cannot impose special category life sentence

This case concerns a criminal appeal by two convicted individuals challenging the sentence imposed by the Trial Court, specifically the direction that they must remain in prison for the rest of their natural lives, which the appellants argue excludes statutory remission and commutation.

Who it concerns: Appellants: Naval Kishore and Jyoti Kumar (Accused Nos. 2 and 3); Respondent: State of Punjab; Bench: Justice Vipul M. Pancholi.

What the court decided

• The Court framed two questions: (A) Whether the Trial Court was competent to direct that appellants remain in prison for the remainder of their lives while imposing a sentence under Section 302 IPC, and (B) If the answer is negative, what sentence is to be imposed.
• The Court noted that the conviction itself did not warrant interference based on a previous order dated 10.11.2025.
• The Court directed the State to place on record a report from the Jail Superintendent regarding the conduct of the appellants in prison.
• The Court observed that Section 302 IPC does not expressly provide that imprisonment for life means imprisonment for the remainder of natural life, unlike other provisions.
• The Court noted that imprisonment for life is subject to statutory powers of remission and commutation under Sections 432-435 Cr.P.C. and Articles 72 and 161 of the Constitution.

Also in the document

• The Court distinguished between an ordinary sentence of imprisonment for life and a 'special category' sentence that excludes statutory remission.
• The Court referenced the decision in Swamy Shraddananda (2) v. State of Karnataka regarding the evolution of a special category of sentence to bridge the gap between death and ordinary life imprisonment.
• The High Court had affirmed the conviction and sentence but did not specifically examine the direction that the accused shall 'remain in prison till rest of their life'.