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Karan Singh v. The State of Haryana

Criminal Appeal · 2025 INSC 475Decided 8 Apr 2025
Crl.A. No.-001840-001840 of 2025 (arising out of SLP (Crl.) No. 12497 of 2024)
Justice B.R. Gavai

Background

The appellant, serving a life sentence for a 2005 murder conviction, was released on a six-week parole in 2010 but failed to surrender on time, leading to a separate conviction and a 2-year rigorous imprisonment sentence under the Haryana Good Conduct Prisoners (Temporary Release) Act, 1988. He challenged the Punjab and Haryana High Court's dismissal of his revision petition against that second conviction, noting he had since been granted remission on his main life sentence.

Decision Breakdown

The Supreme Court found that the 1988 Act (as it stood when the offence occurred in 2010) prescribed only a maximum sentence of three years with no minimum, so the mandatory 2-year minimum introduced by a later 2012 amendment could not apply retroactively. The Court noted the appellant had already served roughly 10 additional months beyond his remission date for the main offence, and held that this time already undergone was sufficient to meet the ends of justice for the parole-violation offence. It set aside the High Court's order and directed his immediate release if not required in any other case.

Lesson Learnt

A later, harsher amendment to a penal statute (such as a newly introduced minimum sentence) cannot be applied to an offence committed before that amendment came into force. The law in force on the date of the offence governs the punishment.

Official source (sci.gov.in)View Judgment (PDF)

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