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Md. Alfaz Ali v. The State of Assam

Special Leave Petition (Criminal) · 2021 INSC 480Decided 14 Sept 2021
Special Leave Petition (Criminal) No. 6220 of 2018
Justice L. Nageswara Rao · Justice B.R. Gavai

Background

The petitioner was convicted of murdering his wife on suspicion of infidelity and sentenced to "rigorous imprisonment for life" under Section 302 IPC; his appeal against conviction was dismissed by the Gauhati High Court. The Supreme Court had earlier restricted its notice to a narrow legal question: whether a trial court is permitted to specify that a life sentence must be "rigorous" (i.e., with hard labour) rather than simply "imprisonment for life."

Decision Breakdown

The Court dismissed the petition, holding that this exact question was already settled by its own earlier decisions, starting with Naib Singh v. State of Punjab and followed in several later cases, which held that a sentence of "imprisonment for life" is legally equivalent to "rigorous imprisonment for life," since life convicts are generally required to perform labour during incarceration in any event. Finding no need to re-examine well-established precedent, the two-judge bench dismissed both connected petitions.

Lesson Learnt

Courts can lawfully describe a life sentence as "rigorous imprisonment for life": this phrasing does not add any additional punishment beyond an ordinary life sentence and is not a valid independent ground for appeal.

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

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