Supreme Court Rules Multiple Life Sentences Cannot Run Consecutively, Preserves Separate Remission Consequences

Operative judgment in the appeal

A Bench of Justices K V Viswanathan and Arun Palli delivered judgment on 27 October 2026 in Raju Shantaram Koli v State of Maharashtra, reported as 2026 INSC 1161. The Court corrected the sentencing direction in a case involving convictions under Section 302 and Sections 376 read with 342 of the Indian Penal Code. It did not overturn the findings of guilt or order the prisoner's release. The appeal was partly allowed only to remove the requirement that one complete life term begin after another.

Background of the trial and earlier appeals

The accused was arrested in April 2010 following allegations of rape and murder of a twelve-year-old child. The Additional Sessions Judge at Thane convicted him in September 2013 and imposed life imprisonment for the offences, along with fines and default terms. The trial court expressly directed that the substantive life sentences run consecutively. In June 2016 the Bombay High Court affirmed the conviction and sentence. A later writ petition seeking concurrent operation was disposed of in January 2025, leading to the proceedings considered by the Supreme Court.

Constitution Bench precedent controls

The Supreme Court relied on Muthuramalingam v State, (2016) 8 SCC 313, a Constitution Bench decision addressing multiple life sentences. Life imprisonment ordinarily extends through the remaining natural life of the prisoner, unless altered by lawful remission or commutation. On that premise, directing one life sentence to start only after another life sentence has been served is conceptually impossible. The Court explained that multiple life sentences can nonetheless be imposed for distinct offences; the prohibition concerns consecutive operation, not the existence of separate convictions or sentences.

Superimposition and remission

The Court directed that the life sentences be superimposed upon each other. This means they operate at the same time, but each remains a legally distinct sentence. If a competent authority grants remission or commutation concerning one sentence, that benefit does not automatically extinguish the other. This is different from treating every sentence as a single interchangeable punishment. The judgment preserves the consequences of multiple serious convictions while avoiding an irrational direction to serve a second lifetime after the first has ended.

What the Court left undisturbed

The Supreme Court retained the operative convictions, fines, default terms and other parts of the trial court's order, except for the consecutive-life-sentence direction. It recorded the period already spent in custody and the set-off directions reflected in the original order. A separate appeal concerning whether a writ court could order concurrent sentences became infructuous once the sentencing issue was resolved in the admitted criminal appeal. Neither the judgment nor the rule it applies guarantees release after a fixed number of years; the applicable remission framework remains relevant.

Importance for sentencing practice

The ruling is a direct application of binding Constitution Bench authority to a trial court sentence. Trial courts must distinguish between awarding a lawful life term for each offence and describing how those terms operate. Appellate courts reviewing sentences should similarly avoid treating consecutive life imprisonment as a device for increasing punishment beyond a human lifespan. The case provides a clear drafting rule for sentencing orders and an equally important qualification for remission decisions. The governing principle is precise: multiple life sentences may coexist, but they cannot run one after another.

Case Details

Raju Shantaram Koli v State of Maharashtra; Criminal Appeals 5072 and 5073 of 2026; 2026 INSC 1161; judgment dated 27 October 2026.

Relevant Bare Act

Code of Criminal Procedure, 1973; relevant provisions: 31, 427(2). The specific legal connection is identified from the verified proceedings and is not a claim that every listed provision was interpreted in the decision.