Multiple Life Sentences Cannot Run Consecutively: India’s Supreme Court

Independently written and published by Shahbaz Shah Legal Journal.

Consecutive life sentences set aside; convictions remain

The Supreme Court of India has reaffirmed that multiple sentences of life imprisonment imposed for offences tried together cannot be served consecutively. In Raju Shantaram Koli v. The State of Maharashtra, the Court removed the direction requiring one life sentence to begin after the other, while maintaining the convictions and the rest of the operative sentencing order. Judgment, paragraphs 15–18.

The reportable judgment, 2026 INSC 1161, was delivered on 27 October 2026 by Justices K.V. Viswanathan and Arun Palli. Justice Viswanathan authored the reasons. Applying the Constitution Bench decision in Muthuramalingam, the Court directed that the life sentences be superimposed over each other. Judgment, paragraphs 13–18; judgment, pages 1 and 12.

That result does not mean acquittal, automatic release or the disappearance of one sentence. The Court expressly preserved the distinction between serving multiple life sentences concurrently and obtaining remission or commutation of each sentence. Relief concerning one does not automatically discharge the other. Judgment, paragraphs 15 and 18.

The conviction and the direction to serve sentences one after another

The appellant had been in custody since 30 April 2010 following allegations of the rape and murder of a 12-year-old child. He was tried in Sessions Case No. 282 of 2010 before the Additional Sessions Judge at Thane, Maharashtra. The present Supreme Court decision concerned the legality of consecutive life sentences, rather than a fresh examination of guilt. Judgment, paragraphs 4–11.

On 27 September 2013, the trial court convicted him under section 302 IPC and imposed life imprisonment with a ₹5,000 fine and a default term. It also imposed life imprisonment for the offences under section 376 read with section 342 IPC, together with the associated fines and default terms recorded in the order. The crucial additional direction required consecutive service of the substantive sentences. Judgment, paragraphs 6–7 and 17.

The Bombay High Court dismissed Criminal Appeal No. 975 of 2014 on 10 June 2016. It confirmed both the convictions and the consecutive-sentence direction. The Supreme Court later entertained a limited challenge to that sentencing arrangement. Judgment, paragraphs 8–11.

Why there were two appeals before the Supreme Court

The appellant first pursued Criminal Writ Petition No. 842 of 2024 seeking concurrent life sentences. On 13 January 2025, the Bombay High Court held that a writ court could not review the earlier judgment of a coordinate bench. It left him free to challenge the sentence before the appropriate court through a legally maintainable route. That order led to the matter arising from SLP (Criminal) No. 8535 of 2025, registered as Criminal Appeal No. 5072 of 2026. Judgment, paragraphs 3; judgment, page 1.

A separate challenge attacked the 2016 appellate judgment itself on the limited issue of consecutive life sentences. That matter arose from Diary No. 49371 of 2026 and SLP (Criminal) No. 20839 of 2026, becoming Criminal Appeal No. 5073 of 2026. Considering the nature of the issue and the appellant’s continuing imprisonment, the Supreme Court condoned delay and granted leave. Judgment, paragraphs 1–4 and 9; judgment, page 1.

Once that direct challenge was admitted, the Court did not need to decide whether the High Court could have granted concurrency through writ jurisdiction. It expressly left that legal question undecided. The eventual disposal of the writ-related appeal must therefore not be described as approval or rejection of that procedural route on its merits. Judgment, paragraphs 12 and 19.

The controlling rule in Muthuramalingam

The Court relied on Muthuramalingam and Others v. State Represented by Inspector of Police, (2016) 8 SCC 313. The Constitution Bench had examined whether life sentences for several offences tried in one trial could run consecutively. Its answer rested on the legal meaning of life imprisonment: ordinarily, imprisonment for the remainder of the offender’s natural life, unless lawfully remitted or commuted. Judgment, paragraphs 13–14.

The reasoning addresses a basic impossibility. If a sentence already covers the prisoner’s remaining lifetime, another life sentence cannot meaningfully begin after the first lifetime has ended. The Court therefore distinguished the lawful award of multiple life sentences from an unlawful direction that they be served one after another. Judgment, paragraphs 14–15.

The Constitution Bench’s discussion, reproduced in this judgment, interprets section 31 CrPC consistently with that meaning of life imprisonment. It also draws on section 427(2), which addresses a further sentence imposed on a person already serving life imprisonment. The present case directly applied the rule to multiple life sentences awarded in a single trial. Judgment, paragraphs 11 and 13–15.

Superimposition preserves the separate sentences

The sentences run together, but they remain legally distinct. The Supreme Court directed that remission or commutation granted by the competent authority in respect of one life sentence would not, by itself, remit the other. Judgment, paragraphs 15 and 18.

That distinction matters when reading a sentence order or a later remission decision. Concurrency answers how imprisonment is served. Remission and commutation concern the legal effect of a competent authority’s subsequent decision on a particular sentence. One cannot assume that an order addressing one conviction removes every independent sentence arising from the case. This is the practical implication of the Court’s express direction. Judgment, paragraphs 14–15 and 18.

The ruling consequently should not be reduced to a claim that the punishment became a fixed number of years. The Court substituted no automatic release date, and it did not treat life imprisonment as a standard 14-year sentence. Its reasoning proceeded from imprisonment for the remainder of life, subject to the applicable powers of remission or commutation. Judgment, paragraphs 14–18.

What changed in the operative order

The Court partly allowed the appeal arising from Diary No. 49371 of 2026. It set aside the High Court’s order only to the extent that it upheld consecutive life sentences, and removed the matching direction from the trial court’s order. The remaining operative provisions were maintained and reproduced. Judgment, paragraphs 16–17.

Those provisions retained the convictions, the life sentences, the fines and default imprisonment, as well as the recorded set-off direction under section 428 CrPC. The Supreme Court added its express direction on superimposition and the separate operation of remission or commutation. It ordered no retrial and no acquittal. Judgment, paragraphs 17–18.

The appeal arising from SLP (Criminal) No. 8535 of 2025 was disposed of as infructuous. The two appeals thus had different outcomes: partial success in the direct sentencing challenge, and disposal of the separate writ-related challenge because it no longer required a decision. Judgment, paragraphs 16–19.

Practical significance for sentencing challenges

The decision provides a focused example of correcting an unlawful sentencing direction while preserving findings of guilt. For a comparable case, the operative orders must be checked to identify whether the court awarded life imprisonment, fixed-term imprisonment or a combination, and whether the challenged direction concerns a single trial. This judgment’s central holding concerns multiple life sentences; it does not make every sentence for every offence concurrent. Judgment, paragraphs 11 and 13–18.

The procedural history also matters. The Supreme Court resolved the direct challenge after condoning delay, without deciding the separate question about writ jurisdiction. The case should therefore be relied on for the sentencing principle it applies, rather than as a general holding that a writ petition can reopen a final criminal appellate judgment. Judgment, paragraphs 1–4 and 12.

Sources and full judgment

• Case details, key principles and paragraph guide.
• Download the complete original judgment PDF.
• Supreme Court of India official judgment entry.
• Official court PDF.

Frequently asked questions

Can two life sentences run consecutively in a single trial?

No. Applying Muthuramalingam, the Supreme Court held that multiple life sentences imposed for offences in a single trial cannot run one after another. They are superimposed over each other.

Did the Supreme Court acquit Raju Shantaram Koli?

No. The convictions and the remaining sentencing directions were maintained. The Court removed the direction requiring consecutive service of the life sentences.

Does this ruling require his immediate release?

No. Life imprisonment ordinarily extends to the remainder of the prisoner’s life, subject to lawful remission or commutation. The judgment contains no immediate release order.

Does remission of one life sentence automatically remit the other?

No. The Court expressly directed that remission or commutation of one sentence does not automatically extend to the other superimposed life sentence.

Did the Court decide whether the High Court could grant concurrency in a writ petition?

No. Because the appellant separately challenged the original appellate judgment and that challenge was admitted, the Supreme Court did not decide the writ-jurisdiction question. The writ-related appeal became infructuous.

What is the citation and where is the complete PDF?

Raju Shantaram Koli v. The State of Maharashtra, 2026 INSC 1161, was decided on 27 October 2026 in Criminal Appeal Nos. 5072 and 5073 of 2026. The unchanged 12-page official judgment is available through the PDF buttons above.