Rajesh v. State of Haryana - Life Imprisonment - Consecutive Or Concurrent

Q&A on the Supreme Court Order (Criminal Appeal No. 4079 of 2025)

Legal Issues and Holdings

What was the central legal issue decided by the Supreme Court?

• The Court addressed whether multiple sentences of life imprisonment can run consecutively or must run concurrently. It held that multiple life sentences cannot run consecutively; they must run concurrently.

What precedent did the Court rely on?

• The Court relied on the Constitution Bench judgment in Muthuramalingam and Ors. vs. State represented by Inspector of Police, (2016) 8 SCC 313, which unequivocally held that multiple life sentences cannot be ordered to run consecutively.

How did the Supreme Court modify the High Court’s sentence?

• It modified the High Court’s direction and ordered that the life sentences awarded to the appellant shall run concurrently, not consecutively.

Why can’t life sentences run consecutively under Indian law?

• As per Muthuramalingam (2016) 8 SCC 313, a life sentence means imprisonment for the remainder of the convict’s natural life. Stacking multiple life terms consecutively is conceptually incompatible because there is only one natural life to serve; therefore, multiple life sentences can only be served concurrently.

Did the Supreme Court interfere with the conviction?

• No. The conviction for the murders of an adult and a minor child and the award of life imprisonment for both offences were not disturbed; only the manner of running the sentences was modified.

What is the operative portion of the Supreme Court’s order?

• The appeal was “partly allowed,” with the specific modification that the life sentences will run concurrently and not consecutively. Pending applications, if any, were disposed of.

Does the order discuss remission or actual period of incarceration?

• No. The order is confined to the direction that multiple life sentences run concurrently. It does not discuss remission, parole, or the actual remissible period—those issues are outside the text of this order.

What happens to fines or default sentences, if any?

• The order does not mention fines or default sentences. The only modification stated concerns the concurrency of the life sentences. Absent any mention, other parts of the sentence remain as previously ordered.

Is this ruling specific to this case, or is it a general rule?

• The rule that multiple life sentences must run concurrently is a general principle settled by the Constitution Bench in Muthuramalingam. The present order applies that binding precedent to this case.

What is the immediate legal effect for the appellant?

• The appellant’s multiple life sentences will now be served concurrently. Practically, this removes the High Court’s direction that would have extended incarceration by stacking life terms.

Case Name and Neutral Citation

• Case Name: Rajesh v. State of Haryana
• Neutral Citation: Criminal Appeal No. 4079 of 2025 (arising from SLP (Criminal) No. 9085 of 2025), Supreme Court of India

Coram (Judges)

• Hon’ble Mr. Justice Pankaj Mithal
• Hon’ble Mr. Justice Prasanna B. Varale

Judgment Date

• 17th September, 2025

Caselaws and Citations Referred

• Muthuramalingam and Ors. vs. State Represented by Inspector of PoliceCitation: (2016) 8 SCC 313
• • This Constitution Bench decision was relied upon for the principle that multiple life sentences must run concurrently, not consecutively.

Statutes/Laws Referred

• Criminal Procedure Code, 1973 (CrPC)
• • Section 31: Deals with the running of sentences for multiple offences (concurrent or consecutive).
• Indian Penal Code, 1860 (IPC)
• • Provisions relating to punishment for murder and life imprisonment (though not explicitly cited, these are the underlying substantive laws for the offences).

Summary of Key References:

• The Supreme Court applied the precedent from Muthuramalingam (2016) 8 SCC 313.
• The relevant procedural law is Section 31 of the CrPC, which governs how sentences are to be served.
• The substantive offence is murder under the IPC.