Multiple murders in a single trial do not constitute “two or more cases” for premature release eligibility.

The petitioner, along with 15 others, was convicted in Sessions Trial No. 38 of 2009 for offences under Sections 148, 302/149 (three counts), 460, 323/149, and 342 of the IPC.

He was sentenced to life imprisonment for three counts of murder arising from a single incident.

Following the dismissal of his appeals by the High Court and the Supreme Court, the petitioner remained incarcerated for over 19 years and 8 months of actual imprisonment (over 22 years including remission).

His application for premature release was rejected by the State on February 2, 2026, on the grounds that Rule 358(6)(ix) of the Chhattisgarh Jail Rules, 1968, barred release because he was convicted for three murders and had not yet completed 20 years of actual incarceration.

The petitioner challenged this rejection, citing satisfactory conduct and parity with a co-accused, Rakesh Sahu, who was granted relief in a similar petition.

1. Whether the phrase "guilty of murder in two or more cases" under Rule 358(6)(ix) of the Chhattisgarh Jail Rules, 1968, applies to a prisoner convicted of multiple murders within a single trial arising from a single incident.

2. Whether the petitioner is entitled to the benefit of premature release based on the principle of parity and the interpretation of the Jail Rules.

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

The constitutional principle of parity under Article 14 to ensure equal treatment of similarly situated co-accused.

The principles established in State of Haryana v. Jagdish (2010) 4 SCC 216 and Laxman Naskar v. State of West Bengal (2000) 7 SCC 626, which require that the consideration for premature release be fair, reasonable, and based on relevant factors rather than mechanical application.

The Court focused on the literal and legal distinction between "multiple murders" and "multiple cases".

It observed that the word "case" in criminal law refers to a distinct prosecution resulting from a separate incident and trial.

Since the petitioner’s convictions (three counts of murder) all stemmed from a single Sessions Trial and a single incident, they did not constitute "two or more cases" as envisioned by Rule 358(6)(ix).

The Court held that the executive authorities committed a manifest error by equating multiple victims in one trial with multiple cases.

The Court noted that a co-accused, Rakesh Sahu, had already been granted the same relief in WPCR No. 108 of 2026, making the denial of the petitioner's application a violation of the principle of parity.

The Court concluded that since the petitioner had served over 19 years and maintained satisfactory conduct, there was no statutory embargo to his release.

It declared that Rule 358(6)(ix) of the Chhattisgarh Jail Rules, 1968, is not applicable to the petitioner’s case as his conviction arose from a single case.

The Court held the petitioner entitled to premature release and directed the respondent authorities to release him forthwith, provided he is not required in any other case, subject to standard terms and conditions.