Distinction Between "Multiple Cases" and "Multiple Murders" for Premature Release Eligibility Under Jail Rules

The petitioner, aged 65, was convicted under Section 302/34 of the IPC and sentenced to life imprisonment in a single sessions trial involving multiple victims

Having completed over 16 years of actual incarceration with satisfactory conduct, he applied for premature release under Section 432 of the Cr.P.C.

His application was supported by the Jail Superintendent and a ‘No Objection Certificate’ from the Trial Court

However, the Under Secretary, Chhattisgarh State Jail Department, rejected his application on 06.04.2026

The rejection was based on a negative recommendation from the State Sentence Review Board, which interpreted Rule 358(6)(ix) of the Chhattisgarh Prison Rules, 1968, as requiring 20 years of actual imprisonment for cases involving multiple murders

1. Whether the expression "guilty of murder in two or more cases" under Rule 358(6)(ix) of the Chhattisgarh Prison Rules, 1968, applies to a convict of multiple murders arising out of a single sessions trial.

2. Whether the rejection of the petitioner’s remission application based solely on the advisory recommendation of the State Sentence Review Board was legally sustainable.

3. Whether the petitioner is entitled to the benefit of parity with a co-accused who was granted similar relief.

Rule 358(6)(ix) of the Chhattisgarh Prison Rules, 1968, which mandates 20 years of actual imprisonment only for those guilty of murder in "two or more cases"

The principle of strict statutory interpretation, distinguishing between "multiple murders" and "multiple cases"

The Supreme Court precedents of State of Haryana v. Jagdish (2010) 4 SCC 216 and Laxman Naskar v. State of West Bengal (2000) 7 SCC 626, which establish that premature release considerations must be fair, reasonable, and based on factors like reformation and conduct

Article 14 of the Constitution regarding the principle of parity in judicial outcomes

The court found that the respondent authorities committed a manifest error by equating "multiple murders" with "multiple cases"

It reasoned that in criminal law, a "case" refers to a distinct prosecution arising from a separate incident; since the petitioner was tried in a single sessions trial, Rule 358(6)(ix) was inapplicable

The court noted that the competent authority failed to exercise independent mind, treating the advisory recommendation of the Review Board as binding while ignoring favorable materials like the Petitioner's 16-year incarceration, his good conduct, and the Trial Court’s NOC

Furthermore, the court emphasized that a co-accused, Rakesh Sahu, had already been granted similar relief in WPCR No. 108 of 2026, making the denial to the petitioner a violation of the principle of parity

The court allowed the writ petition, quashed the impugned order dated 06.04.2026, and directed the respondent authorities to release the petitioner forthwith, subject to usual terms and conditions.