In this criminal appeal arising from the conviction of the appellant for the rape and murder of a 12-year-old victim, the Supreme Court examined whether multiple life sentences imposed in a single trial can be directed to run consecutively. A Bench led by Justice K.V. Viswanathan, relying on the Constitution Bench precedent in Muthuramalingam v. State, held that since a human being has only one life, life sentences awarded for multiple offences cannot run consecutively. Instead, multiple life sentences must run concurrently by being superimposed over each other. This ensures that any remission or commutation granted by the competent authority for one sentence does not ipso facto result in the remission of the other. Consequently, the Court set aside the consecutive nature of the sentences and modified them to superimposed life sentences.
1. Factual Matrix & Background
- Arrest & Trial: The appellant was arrested on April 30, 2010, for the rape and murder of a 12-year-old victim committed on April 29, 2010. He faced trial in Sessions Case No. 282/2010 before the Additional Sessions Judge, Thane.
- Trial Court Conviction: On September 27, 2013, the Trial Court convicted the appellant under Section 302 IPC (imprisonment for life with a fine of ₹5,000) and under Section 376 read with Section 342 IPC (imprisonment for life with a fine of ₹5,000). Crucially, the Trial Court ordered that these substantive life sentences run consecutively (one after the other).
- High Court Confirmation: On June 10, 2016, the Bombay High Court confirmed the conviction and the consecutive nature of the sentences.
- Appeals Before the Supreme Court: The appellant approached the Supreme Court challenging both the High Court’s refusal to direct concurrent sentences via a writ petition and the substantive legality of imposing consecutive life sentences.
2. Key Legal Issues & Supreme Court Findings
- legality of Consecutive Life Sentences:
- Holding: Multiple sentences of imprisonment for life awarded in a single trial cannot be directed to run consecutively.
- Reasoning: Relying on the Constitution Bench ruling in Muthuramalingam v. State Represented by Inspector of Police, the Court reiterated that life imprisonment means imprisonment for the remainder of the offender’s natural life. Because human beings have only one life to live, any direction requiring an offender to undergo life imprisonment “twice over” is legally impossible, anomalous, and irrational.
- Concept of “Superimposition” of Life Sentences:
- Holding: When multiple life sentences are awarded, they do not run consecutively; rather, they superimpose over each other.
- Reasoning: Superimposition means that the life sentences run concurrently in practice, but with a crucial legal caveat: if the prisoner is granted the benefit of remission or commutation by a competent authority for one sentence, that benefit does not ipso facto extend to the other sentence.
- Disposal of Connected Matters:
- Since the main appeal challenging the sentence was entertained and heard on merits, the separate criminal appeal (arising from SLP (Crl.) No. 8535 of 2025) seeking a direction from a writ court for concurrent sentences was disposed of as having become infructuous.
3. Final Operative Directions
- Partial Allowance: The criminal appeal is partly allowed. The lower court directions ordering the life sentences under Section 302 and Section 376/342 IPC to run consecutively (or concurrently) are set aside.
- Superimposition Ordered: The dual life sentences shall superimpose over each other, ensuring that remission or commutation granted for one does not automatically apply to the other.
- Sentence Integrity Maintained: The conviction, fine defaults, and statutory set-off (under Section 428 CrPC for the period already undergone since April 30, 2010) remain intact.



