Multiple Life Sentences in a Single Trial Cannot Run Consecutively; Remission of One Does Not Automatically Affect the Other: Supreme Court

Case Name: Raju Shantaram Koli v. State of Maharashtra

Date of Judgment: 27 October 2026

Citation: 2026 INSC 1161

Bench: Justice K.V. Viswanathan and Justice Arun Palli

Held: The Supreme Court held that multiple sentences of life imprisonment imposed for offences tried in a single trial cannot be directed to run consecutively. Relying on the Constitution Bench decision in Muthuramalingam v. State, (2016) ,the Court reiterated that life imprisonment ordinarily means imprisonment for the remainder of the convict’s natural life, unless the sentence is lawfully remitted or commuted. Multiple life sentences must therefore be superimposed over one another. Remission or commutation granted in respect of one sentence does not automatically extend to the other.

Summary: The appellant, Raju Shantaram Koli, was convicted by the Sessions Court for the rape and murder of a 12-year-old victim. In 2013, the trial court imposed life sentences for the offences under Section 302 and Section 376 read with Section 342 of the Indian Penal Code, 1860, and directed the substantive sentences to run consecutively. The Bombay High Court affirmed the conviction and sentence in 2016, including the direction for consecutive sentences.

The appellant subsequently sought a direction that the life sentences run concurrently. His writ petition was disposed of by the High Court, which held that a writ court could not review the earlier judgment of a coordinate Bench and left him free to challenge the sentence before the appropriate court. The appellant separately challenged the 2016 judgment before the Supreme Court on the limited question of whether the life sentences could run consecutively.

The Supreme Court applied the Constitution Bench ruling in Muthuramalingam, which explained that a person has only one life and cannot serve a second life sentence after completing the first. While a court may impose multiple life sentences for separate offences, those sentences must operate concurrently by being superimposed. The Court also clarified the consequence for remission: relief granted in respect of one life sentence does not, by itself, extinguish the other.

Since the Court admitted the separate appeal against the 2016 judgment and decided the sentencing issue in that appeal, it found it unnecessary to decide whether the High Court, in writ jurisdiction, could have directed the sentences to run concurrently.

Decision: The Supreme Court partly allowed the appeal against the 2016 judgment and set aside the direction that the substantive sentences run consecutively. It directed that the life sentences be superimposed over each other, while maintaining the remaining parts of the trial court’s operative order as affirmed by the High Court, including the convictions and sentences.