Supreme Court Reaffirms Exclusive Authority of Constitutional Courts in Life Imprisonment Sentences

Sessions Courts Cannot Impose Life Imprisonment Till Natural Life or Restrict Remission Rights, Rules Apex Court

In a significant judgment delivered on December 18, 2025, the Supreme Court of India clarified the limits of sentencing powers of Sessions Courts in imposing life imprisonment sentences. The decision came in the case of "Kiran v. State of Karnataka," where the court addressed whether a Sessions Court could sentence an individual to life imprisonment till the end of their natural life and restrict statutory rights of remission and commutation.

The bench, comprising Justices Ahsanuddin Amanullah and K. Vinod Chandran, ruled that the power to impose life sentences without remission lies exclusively with Constitutional Courts, such as the High Courts and the Supreme Court, particularly in heinous crimes that do not warrant the death penalty.

The case involved a tragic incident where a widow with five children was burned alive by a relative for resisting his advances. The trial court had sentenced the accused to life imprisonment till the end of his natural life, without the benefit of remission. However, the Supreme Court found this direction to be beyond the trial court's jurisdiction.

Justice K. Vinod Chandran, delivering the judgment, emphasized that while life imprisonment technically spans the entire life of the convict, remission and commutation rights under the Indian Penal Code (IPC) and Code of Criminal Procedure (CrPC) cannot be curtailed by Sessions Courts. Instead, the power to impose alternative sentencing without remission is reserved for Constitutional Courts, which can utilize this option in rare cases as a substitute for the death penalty.

The judgment referred to precedents such as "Swamy Shraddananda (2) v. State of Karnataka" and "Union of India v. V. Sriharan alias Murugan," reaffirming that the authority to impose sentences without remission is a prerogative of higher courts. The court further clarified that the trial court's directive not to grant a set-off for detention during the trial was invalid and should be removed.

In light of this, the Supreme Court modified the sentence to life imprisonment, allowing the accused to seek remission and commutation in due course, subject to governmental policy. The ruling reinforces the hierarchical structure of sentencing powers within the Indian judicial system, ensuring that severe punishments like life imprisonment without remission are judiciously applied.

Bottom Line:

Life imprisonment under Section 302 IPC - Sessions Courts lack the authority to impose life imprisonment till the end of natural life or curtail remission and commutation rights under Sections 432-435 Cr.PC. The constitutional courts, i.e., the High Courts and the Supreme Court, have exclusive jurisdiction for alternative sentencing in heinous cases.

Statutory provision(s):  

- Indian Penal Code, 1860 - Section 302  

- Code of Criminal Procedure, 1973 - Sections 428, 432 to 435  

- Constitution of India - Articles 72 and 161

Kiran v. State of Karnataka, (SC) : Law Finder Doc Id # 2823497