State must provide reasonable, logical reasons when rejecting remission applications under Chhattisgarh prison rules.

The petitioner was convicted under Sections 302/34 of the IPC and sentenced to life imprisonment on 25.07.2013

Following the dismissal of his appeals by the High Court and the Supreme Court in 2020, the petitioner applied for remission under Section 432 Cr.P.C. after completing 14 years, 3 months, and 19 days of incarceration

Although Respondent No. 5 (Jail Superintendent) recommended the application, the State Government (Respondent No. 3) rejected the claim on 22.03.2026 based on the heinous nature of the crime and negative recommendations from the State Sentence Review Board

The petitioner challenged this rejection as arbitrary and non-speaking

1. Whether the State Government's rejection order dated 22.03.2026 complied with the mandatory requirements of assigns "reasonable and logical reasons" under the Chhattisgarh Prison Rules, 1968

2. Whether the discretionary power of remission under Section 473 of the BNSS (formerly Section 432 Cr.P.C.) was exercised based on an objective consideration of all relevant materials

Section 473 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 (corresponding to Section 432 of the Cr.P.C.), which governs the power to suspend or remit sentences

The amended Rule 358 of the Chhattisgarh Prison Rules, 1968, which mandates an inquiry into eleven specific points, including the opinion of the sentencing Court, reports from the Collector and Superintendent of Police, and the prisoner's conduct

Sub-rule (7)(vii), which requires that any order of rejection by the State must contain reasonable and logical reasons

Article 14 of the Constitution requires such discretionary powers to be exercised without arbitrariness

The Court found that the impugned rejection order was "wholly non-speaking" and failed to satisfy the mandatory requirements of Rule 358

While the State argued that remission is discretionary and the offence was grave, the Court reasoned that the authorities ignored several critical factors in their subjective satisfaction: the petitioner’s 14-year incarceration, his satisfactory jail conduct, his successful parole history without adverse reports, and the favorable "no objection" opinion from the Presiding Judge

The Court noted that the State's reliance on a "generalized apprehension" of societal impact and the gravity of the offence, without addressing the specific rehabilitation milestones required by law, rendered the decision arbitrary and a failure of the decision-making process

The High Court allowed the writ petition, set aside the impugned order dated 22.03.2026, and directed the respondent-State to forthwith take necessary steps for the premature release of the petitioner in accordance with law