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Supreme Court of India 2020-09-30 partly_allowed

Satish @ Sabbe vs The State of Uttar Pradesh

Bench: 3 — N.V. Ramana, Surya Kant, Hrishikesh Roy

In Brief

Two petitioners convicted of kidnapping for ransom under IPC Section 364-A were sentenced to life imprisonment. After nearly two decades of incarceration with good conduct and no criminal antecedents, they sought premature release on probation. The State repeatedly refused without applying statutory criteria. The Supreme Court held that when a statute prescribes conditions for premature release, the executive cannot arbitrarily ignore them. The Court directed release on probation, finding that gravity of crime and age alone cannot justify refusal. The Court emphasised that assessment must be based on actual conduct and antecedents, not victim apprehensions. Release was granted subject to continuing good conduct and conditions, with power to recall for breach.

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Criminal Law Remission and Probation Sentencing Constitutional Law Judicial Review Executive Discretion Prison Reform Human Rights Criminal Procedure

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