Case Summary: Muthuramalingam & Others v. State Rep. By Inspector of Police
Citation: (2016) 07 SC CK 0052; (2016) 8 SCC 313; AIR 2016 SC 3340
Date of Judgment: July 19, 2016
Bench: T.S. Thakur, CJI; F.M.I. Kalifulla; A.K. Sikri; S.A. Bobde; R. Banumathi, JJ.
Court: Supreme Court of India (Constitution Bench)
[Judgment Source] https://www.courtkutchehry.com/Judgement/Search/AdvancedV2?docid=1027896
Law Points Raised
1. Whether courts can impose consecutive life sentences for multiple murders committed in a single trial. (§1, §3)
2. Interpretation of Section 31(1) and (2) of CrPC regarding multiple punishments. (§6, §7)
3. Whether 'life imprisonment' truly means imprisonment for the rest of natural life. (§9, §10)
Ratio Decidendi
• Life imprisonment means incarceration for the remainder of the convict's natural life. (§9–§13)
• Consecutive life sentences can be imposed in rarest of rare cases to reflect the gravity of multiple murders. (§19)
• However, Section 31 CrPC should be read subject to the limitation that actual imprisonment shall not exceed 14 years unless remitted. (§7)
Final Ruling
The Constitution Bench upheld that life imprisonment denotes jail till the end of natural life. (§10) Consecutive life sentences are not barred but are often redundant since life imprisonment means full life unless remission is granted. (§13–§14) The appeals were disposed of by clarifying the above legal position. (§19)
Key Paragraphs for Reference
§1 – Framing of legal question
§3 – Factual matrix and background
§6–§7 – Interpretation of Section 31 CrPC
§9–§13 – Precedents on the meaning of life imprisonment
§19 – Conclusion and final pronouncement