Satpal & Another vs State Of Haryana & Ors

The Supreme Court examined the validity of the Governor's pardon under Article 161 of the Constitution and Section 132 of the Code of Criminal Procedure, which was challenged on grounds of lack of application of mind and extraneous considerations. The Court emphasized that the Governor must act on the advice of the Council of Ministers, and the decision to grant pardon must be based on proper legal advice. The Court ultimately held that the Governor's order was invalid as it did not adhere to the constitutional mandate, leading to the quashing of the pardon granted to Siriyans Kumar Jain.