Can a Sessions Court Deny Remission for Life? Supreme Court Sets Aside “Prison for Rest of Life” Direction in Murder Case

Case Name: Naval Kishore & Anr. v. State of Punjab

Date of Judgment: 24 September 2026

Citation: 2026 INSC 1048

Bench: Aravind Kumar and Vipul M. Pancholi, JJ.

Held: A trial court may sentence a person convicted of murder to imprisonment for life, but it cannot direct that the person remain in prison for the rest of their natural life in a manner that excludes statutory remission or commutation. The power to impose such a special category of sentence lies with a constitutional court. The Sessions Court’s additional direction was therefore beyond its authority, although the conviction and the imposition of life imprisonment were valid.

Summary: The appellants were convicted under Section 302 read with Section 34 of the Indian Penal Code in a case involving the murder of a woman and her two minor daughters. The Sessions Court imposed rigorous imprisonment for life and added that the convicts must remain in prison for the rest of their lives. The High Court affirmed the conviction and sentence without separately examining that direction. Before the Supreme Court, the issue was confined to sentencing. The Court held that the Sessions Court could impose life imprisonment but could not itself bar the operation of the statutory remission and commutation regime. Considering the gravity of the crime, the appellants’ respective roles, the time already spent in custody and their conduct in prison, the Supreme Court determined that a fixed term of 25 years without statutory remission was appropriate.

Decision: The appeal was allowed in part. The conviction under Section 302 read with Section 34 IPC was affirmed. The direction to remain in prison for the rest of their lives was set aside, and both appellants were sentenced instead to 25 years’ rigorous imprisonment without statutory remission.