The Supreme Court of India, in a significant ruling on criminal sentencing, has held that when an accused is awarded multiple sentences of life imprisonment, the sentences must run concurrently and not consecutively. A bench comprising Justice Pankaj Mithal and Justice Prasanna B. Varale modified a judgment of the High Court of Punjab & Haryana, which had directed a convict to serve two life sentences one after the other.
The order was passed in Criminal Appeal No. 4079 of 2025, filed by the appellant, Rajesh, against the State of Haryana.
Background of the Case
The appellant, Rajesh, had been convicted for the murder of an adult and a minor child. For these two distinct offences, he was awarded life imprisonment for each. The High Court of Punjab & Haryana, in its final judgment and order dated April 10, 2015, had directed that the two life sentences were to run consecutively. This meant the appellant would have to serve the second life sentence only after the completion of the first.
Aggrieved by this direction, the appellant filed a Special Leave Petition in the Supreme Court, which was granted, and the matter was heard as a criminal appeal.
Arguments of the Appellant
During the hearing, counsel for the appellant, Rajesh, submitted that the High Court’s direction for the sentences to run consecutively was contrary to established legal principles. The core of the argument was that “when multiple sentences of life imprisonment are awarded, they have to run concurrently and not consecutively.”
In support of this submission, the appellant’s counsel relied on the Constitution Bench decision of the Supreme Court in the case of Muthuramalingam and Ors. vs. State Represented by Inspector of Police ((2016) 8 SCC 313).
Supreme Court’s Analysis and Decision
The Supreme Court bench examined the precedent cited by the appellant. The Court noted that the legal position on this issue had been clearly settled in the Muthuramalingam case.
Referring to the aforementioned decision, the Court observed that it had been laid down “in unequal terms… that if multiple sentences of life imprisonment are awarded, the same cannot be directed to run consecutively, they can only run concurrently.”
Accepting the submission of the appellant and relying on the binding precedent, the Supreme Court concluded that the direction issued by the High Court was incorrect.
In its final order dated September 17, 2025, the Court stated, “In view of the aforesaid facts and circumstances, the impugned judgment dated 10.04.2015 passed by the High Court is modified and the sentences awarded to the appellant for life are directed to run concurrently and not consecutively.”
The appeal was thus partly allowed, and the pending applications were disposed of.
