Rishi Rallan vs State Of Nct Of Delhi

Court
Delhi High Court

$~104
* IN THE HIGH COURT OF DELHI AT NEW DELHI
%
Date of Decision: 27.10.2026
# CNR No.DLHC010512362026
+ W.P.(CRL) 3346/2026
RISHI RALLAN .....Petitioner
Through: Mr. Siddharth Sunil, Adv.
versus
STATE OF NCT OF DELHI .....Respondent
Through: Ms. Rupali Bandhopadhya, ASC for
the State.
CORAM:

HON'BLE MR. JUSTICE SACHIN DATTA

SACHIN DATTA, J. ( Oral .)


CRL.M.A. 33428/2026 (Exemption from filing certified copies of annx.)

1. Allowed, subject to all just exceptions.
2. The application stands disposed of.
W.P.(CRL) 3346/2026 & CRL.M.A. 33427/2026 (Seeking Ad-Interim
Extension of Furlough)
3. The petitioner is serving imprisonment for life and was convicted in

FIR No. 170/2010, registered at P.S. Paharganj, Delhi, under Sections
302/120B of the Indian Penal Code, 1860.
4. Vide order dated 05.10.2026, in W.P. (Crl.) No. 2561/2026, this Court
set aside the order rejecting the petitioner’s application for the first spell of
furlough. The said rejection was based only on the punishment of warning.
He was directed to be released on furlough for 21 days.
5. It is submitted that pursuant to the aforesaid order, the petitioner was
released on 07.10.2026 and is due to surrender on 28.10.2026. It is admitted
that his conviction year ends on 13.02.2027. The petitioner, by way of the
W.P.(CRL) 3346/2026 Page 1 of 6



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Digitally Signed By:ROHIT
KUMAR PATEL
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present petition, seeks extension of furlough by four (4) weeks.
6. It is pleaded that upon being released, the petitioner visited his
residential and ancestral house bearing No. 2731, Gali No. 7, near Police
Chowki, Chuna Mandi, Paharganj, New Delhi-110055, and found the same
in acutely dilapidated condition. It is submitted that he has no family in
Delhi to supervise the repairs, which require 3 to 4 weeks of continuous
work. The petitioner prays that the extended period be adjusted against the
remaining furlough entitlement for the current conviction year. It is
submitted that his representation dated 09.10.2026 to the concerned
authorities for extension/ further spell of furlough is stated to be pending.
7. Learned counsel for the State vehemently opposes the present

petition. It is submitted that the Delhi Prison Rules, 2018 do not provide for
extension of a spell and that a prisoner can be considered only for the next
spell of furlough in accordance with the Rules. In this regard, reliance has
been placed on the order dated 14.07.2025 passed in Zafar Ul Islam v. State
of NCT of Delhi , W.P. (Crl) 2518/2022 .
REASONING
8. It is well settled that furlough is a humanistic measure. The same has
been affirmed by the Supreme Court in Asfaq v. State of Rajasthan , (2017)
15 SCC 55 , in the following terms:
“ 18. The provisions of parole and furlough, thus, provide for a
humanistic approach towards those lodged in jails. Main purpose of
such provisions is to afford to them an opportunity to solve their
personal and family problems and to enable them to maintain their
links with society . Even citizens of this country have a vested interest
in preparing offenders for successful re-entry into society. Those who
leave prison without strong networks of support, without employment
prospects, without a fundamental knowledge of the communities to
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KUMAR PATEL
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which they will return, and without resources, stand a significantly
higher chance of failure. When offenders revert to criminal activity
upon release, they frequently do so because they lack hope of
merging into society as accepted citizens. Furloughs or parole can
help prepare offenders for success
. ”
(emphasis supplied)

9. The aforesaid observation can be noted against the objectives of
parole and furlough enunciated in Rules 1197 and 1200 of the Delhi Prison
Rules, 2018, which are extracted hereunder:
“ 1197. Parole and Furlough to inmates are progressive measures of
correctional services. The release of a prisoner on parole not only
saves him from the evils of incarceration but also enables him to
maintain social relations with his family and community. It also
helps him to maintain and develop a sense of self-confidence
.
Continued contact with family and the community sustains in him a
hope for life. The release of prisoner on furlough motivates him to
maintain good conduct and remain disciplined in the prison. ”
“ 1200. The objectives of releasing a prisoner on parole and furlough
are:
i. To enable the inmate to maintain continuity with his family life
and deal with familial and social matters
ii. To enable him to maintain and develop his self-confidence,
,
iii. To enable him to develop constructive hope and active interest in
life
iv. To help him remain in
,
touch with the developments in the outside
world
v. To help him remain physiologically and psychologically healthy,
,
vi. To enable him to overcome/recover from the stress and evil effects
of incarceration
vii. To motivate him to maintain good conduct and discipline in the
prison... ”
, and
(emphasis supplied)
10. Qua the question of extension of furlough, reference may be made to
the judgment, dated 21.07.2025, of the Coordinate Bench of this Court in
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Digitally Signed By:ROHIT
KUMAR PATEL
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Dinesh Kumar versus State of NCT of Delhi , W.P (Crl.) 684/2025 , wherein
it has been observed as under:
“ 8. The Court has considered the submissions advanced by the
Petitioner. Owing to the absence of any statutory provision for
extension of furlough, the Court is unable to accede to the Petitioner’s
request. In this background, Ms. Vrinda Bhandari, counsel for the
Petitioner, on instructions, submits that instead the Petitioner be
released on second spell of furlough and accordingly, seeks relaxation
of Rule 13 of Standing Order 01/2019.
9. The Respondents have highlighted the mandatory one-month
interval between two furloughs as stipulated under Point 13 of
Standing Order No. 01/2019 , issued by the Prison Headquarters.
However, it is pertinent to note that Point 13 also permits relaxation
of this requirement by the Competent Authority in cases involving
emergent circumstances, including medical conditions affecting
family members
.
*
12. It must be noted that the provision of furlough is a benevolent
one and is designed for the welfare of prisoners. The provision has
the intent of rewarding prisoners for their good behaviour, when
traces of reformation can be seen in them.
Considering that the
Petitioner’s request for furlough is based on the bona fide grounds of
his son’s deteriorating health, and in light of his own medical
ailments, his request for second spell of furlough is allowed with effect
from 25th July, 2025 on the same terms and conditions as order dated
5th June, 2025, passed by the Director General of Prisons, Prison
Headquarters, Tihar. ”
(emphasis supplied)
11. It is also noticed that the Standing Orders allow the relaxation of the
cooling period in case of emergent circumstances. Furthermore, various
Coordinate Benches of this Court have granted extension of furlough in
multiple matters, such as: Jasbir Kaur v. State of NCT of Delhi
, W.P. (Crl)
(19.06.2026), Ramesh Dudhiya v. State (NCT of Delhi)
1793/2026 , W.P.
(Crl) 2916/2026 (18.09.2026), and Pradeep Kumar @ Sonu v. State NCT
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of Delhi , W.P. (Crl) 2103/2026 (30.07.2026). Accordingly, there is no
embargo on this Court from extending the period of furlough in appropriate
circumstances.
12. Reference would also be apposite to the Punjab & Haryana High
Court’s decision, dated 31.10.2025, in Bahadur Singh v. State of UT
Chandigarh , 2025:PHHC:149797 , wherein the Court, while dealing with a
matter of similar nature, passed the following order:
“ 2. Learned counsel appearing on behalf of the petitioner contends
that the petitioner was convicted and sentenced to life imprisonment
for commission of offence under Section 302 of the Indian Penal
Code, 1860 in case FIR No.66 dated 11.05.1998 registered at Police
Station Sector-11 Chandigarh … He further contends that due to the
onslaught of heavy rains, the construction raised at the field as well
as the house has suffered damage which needs to be repaired.
Although ardent effort has been made by the petitioner to undertake
the said repairs during the 14 days’ furlough that had been granted
to him, however, the said work could not be completed as a result of
the Diwali festivities and non-availability of labour. He further
contends that it shall take another four weeks for him to complete
the entire construction
.
*
7. Accordingly, the furlough of 14 days’ granted to the petitioner
vide order dated 04.06.2025 (released w.e.f. 16.10.2025) is extended
for a period of 04 (four) weeks
. The petitioner shall surrender before
the Jail Authorities on or by 30.11.2025. ”
(emphasis supplied)
13. Considering the facts and circumstances, the present petition is
allowed. The furlough of the petitioner is extended by 04 weeks. The same
shall be subject to the same conditions as previously imposed. The petitioner
shall surrender to the jail authorities upon expiry of the said period. The
extended period shall be adjusted against the petitioner’s entitlement for the
conviction year ending on 13.02.2027.
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Signature Not Verified
Digitally Signed By:ROHIT
KUMAR PATEL
Signing Date:28.10.2026
17:57:27

14. The petition, along with the application, stands disposed of in the
above terms.

SACHIN DATTA, J
OCTOBER 27, 2026/ uk/vk

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Signature Not Verified
Digitally Signed By:ROHIT
KUMAR PATEL
Signing Date:28.10.2026
17:57:27