Life imprisonment runs for natural life; additional fixed-term sentences cannot run consecutively to a life term.

The Petitioner was convicted in 1992 for the murder of three family members and the gang rape of a woman

In 1998, the Supreme Court commuted his death sentence to life imprisonment but specifically directed that while other sentences would run concurrently, his 10-year sentence under Section 376(2)(g) IPC for gang rape must run consecutively after the completion of his life sentence

On 19th September 2025, the State Government issued an order under Section 433A of the CrPC, fixing the Petitioner's period of release after 30 years of imprisonment (including remission) but mandated he serve an additional 10 years for the rape conviction as per the Supreme Court's 1998 directions

The Petitioner challenged this additional 10-year requirement

Whether a fixed-term sentence (10 years) can be directed to run consecutively after a sentence of life imprisonment

Whether the State's order requiring the Petitioner to undergo an additional 10-year term after his life term is legally sustainable in light of subsequent Constitution Bench precedents

The Court applied Section 31 of the CrPC and Section 433A of the CrPC regarding the power of remission and the nature of life imprisonment

It primarily relied on the Constitution Bench decision in Muthuramalingam & Ors. v. State (2016) 8 SCC 313, which established that since life imprisonment means imprisonment for the full span of natural life, no other sentence can run consecutively to it

It also cited Duryodhan Rout v. State of Orissa (2015) 2 SCC 783, confirming that life imprisonment is not a fixed term of 14 or 20 years but lasts for the remainder of the convict's life unless remitted

The Court noted that the 1998 Supreme Court judgment in the Petitioner's own case (Ronny v. State of Maharashtra) had indeed ordered the sentences to run consecutively

However, the 2016 Constitution Bench in Muthuramalingam specifically reviewed that exact judgment and held that to the extent it allowed a life sentence to run consecutively with another term, it "does not lay down the correct law and shall stand overruled"

The Court reasoned that because "life imprisonment" encompasses the entirety of a person's natural life, there is no "after" for a consecutive sentence to begin

While the State's determination of a 30-year threshold for the life term (under the 1992 Guidelines) was found reasonable given the Petitioner's conduct and abscondence for 1150 days

The State erred by failing to recognize that the consecutive sentencing portion of the 1998 order had been overruled by the Constitution Bench

It held that while multiple life sentences or terms are superimposed, they cannot run consecutively

The Court confirmed the State’s order insofar as it requires the Petitioner to complete 30 years of imprisonment (including remission)

Quashed and set aside the direction requiring him to undergo a further 10 years of imprisonment under Section 376(2)(g) IPC

The impugned order of 19th September 2025 was modified accordingly