Supreme Court Says Life Imprisonment Can Be Modified Into Fixed-Term Sentence, Orders Release Of Murder Convicts After 23 Years In Jail

In Munna Moyuddin Shaikh Versus State of Gujarat, the Supreme Court has reiterated that a life imprisonment sentence can be modified into a fixed-term sentence when a convict has already undergone a long period of incarceration. The Court observed that such modification is legally permissible even though life imprisonment ordinarily means imprisonment for the remainder of natural life.

A bench of Justice K.V. Viswanathan and Justice Vijay Bishnoi delivered the judgement while hearing appeals filed by convicts who had already spent nearly 23 years in prison in a murder case. The Gujarat High Court had earlier upheld both their conviction and the sentence of life imprisonment imposed by the trial court.

The Supreme Court refused to interfere with the findings related to conviction. However, it accepted the argument raised by the appellants seeking modification of their sentence. The Court noted that constitutional courts have the power to convert a life sentence into a fixed-term sentence in appropriate cases where the convict has already undergone substantial imprisonment.

The bench observed, “…when a sentence of life imprisonment is imposed, Section 53 read with Section 45 of the IPC would convey the meaning that it is till the natural life subject to the right of claiming remission. Hence, modifying a sentence of life imprisonment and imposing a fixed sentence is permissible…”

The Court relied on its earlier ruling in Shiva Kumar versus State of Karnataka and also considered the principles laid down in Union of India v. V. Sriharan. The appellants argued that after completing more than 14 years in prison, they were entitled to seek modification of their sentence from life imprisonment to a fixed period already undergone.

Accepting this contention, the Court modified the sentence to the period already undergone by the convicts. As a result, while their conviction for murder remained intact, the Supreme Court directed their release from prison.

The ruling once again clarifies the distinction between conviction and sentencing powers exercised by constitutional courts. It also highlights that long incarceration, coupled with judicial discretion, can justify modification of punishment in deserving cases.