SATPAL @ SADHU vs STATE OF HARYANA

The Supreme Court dismissed the writ petition of a life convict sentenced under Section 302 IPC, who claimed entitlement to release after serving 13.5 years of actual imprisonment and 17 years total, arguing that the Government must be deemed to have commuted his sentence to 14 years under Section 55 IPC and Section 433(b) CrPC. The Court held that without a formal order of commutation from the appropriate Government, the petitioner was not entitled to release. The judgment reaffirmed that life imprisonment entails rigorous imprisonment and cannot be deemed commuted without explicit governmental action.