SHAIK ABDUL AZEEZ vs STATE OF KARNATAKA

The Supreme Court held that Section 303 IPC applies only to individuals who are actually undergoing a sentence of imprisonment for life at the time of committing a subsequent murder. The Court clarified that a person whose life sentence has been conditionally remitted under Section 401 of the CrPC is not considered 'under sentence of imprisonment for life' for the purposes of Section 303 IPC. Consequently, the Court modified the death sentence to life imprisonment, as the appellant was not under an operative sentence at the time of the second offence.