Multiple Life Sentences Cannot Run one after another in Single Trial: Supreme Court

Humans have but one life to live, making it a legal impossibility to serve two consecutive life imprisonment terms awarded in a single trial. Reaffirming this foundational criminal jurisprudence, the Supreme Court ruled that multiple life sentences imposed for distinct offences must run concurrently by being superimposed over one another. A Bench comprising Justice K.V. Viswanathan and Justice Arun Palli addressed a challenge to a High Court order that affirmed a trial court's decision directing consecutive life sentences for murder and rape in a single trial.

Multiple Life Sentences

Summarizing the core legal bar against consecutive life terms, the Supreme Court relied heavily on the settled position of law. The Bench emphasized that since life imprisonment extends to the remainder of the natural life of a convict, directing a person to undergo life sentences consecutively creates an impossible legal anomaly.

The Supreme Court, in its reasoning, observed that "The correct legal position, as set out by this Court in Muthuramalingam and Others vs. State Represented by Inspector of Police ( "(2016) 8 SCC 313": 2016 CaseBase(SC) 1178) is, life sentences awarded for multiple offences in a single Trial, cannot be directed to run consecutively. However, such sentences would be super imposed over each other so that any remission or commutation granted by the competent authority qua one, does not ipso facto result in remission of sentence awarded to the prisoner for the other."

The Apex Court issued the following directions:

"We further direct, in accordance with Muthuramalingam and Others vs. State Represented by Inspector of Police ( "(2016) 8 SCC 313": 2016 CaseBase(SC) 1178), that the life sentence imposed for the offence punishable under Section 302 and the life sentence imposed for the offences punishable under Section 376 read with 342, shall be superimposed over each other so that any remission or commutation granted by the competent authority qua one, does not ipso facto result in the remission of the sentence awarded to the prisoner for the other."

Background

The appellant was arrested on April 30, 2010, for the rape and murder of a 12-year-old child. By a judgment dated September 27, 2013, the Additional Sessions Judge, Thane, convicted him under Section 302 of the Indian Penal Code, 1860 and sentenced him to life imprisonment with a fine. He was separately convicted under Section 376 read with Section 342 of the Indian Penal Code, 1860 and sentenced to another term of life imprisonment with fine. The trial court specifically ordered that both substantive sentences of life imprisonment would run consecutively, one after the other.

Upon appeal, the High Court of Judicature at Bombay affirmed both the conviction and the direction for consecutive sentences on June 10, 2016. Subsequent proceedings filed under writ jurisdiction seeking concurrent execution were turned down, leading the appellant to approach the Supreme Court.

Analyzing the statutory scheme of Section 31 of the Code of Criminal Procedure alongside precedent established in Muthuramalingam and Others vs. State Represented by Inspector of Police ( "(2016) 8 SCC 313": 2016 CaseBase(SC) 1178), the Supreme Court partially allowed the appeal. The Apex Court set aside the directions of the trial court and High Court to the extent they mandated consecutive execution, holding that both life sentences shall be superimposed over each other.

Case Details:
Case No.: Criminal Appeal No. 5072 of 2026
Neutral Citation: 2026 INSC 1161
Case Title: Raju Shantaram Koli v. The State of Maharashtra
Appearances:
For the Petitioner(s): Mr. M.Y. Deshmukh, Learned Counsel
For the Respondent(s): Mr. Bharat Bagla, Learned Counsel

Source: 2026 CaseBase(SC) 9499