SATPAL vs STATE OF HARYANA

The Supreme Court examined the validity of the Governor's pardon granted under Article 161 of the Constitution and Section 132 of the Code of Criminal Procedure. The Court held that the exercise of this power must be based on proper application of mind and not on extraneous considerations. The Court set aside the Governor's order, emphasizing that the Governor must act on the advice of the Council of Ministers, and the decision to grant pardon was found to be flawed due to lack of proper consultation and consideration of the gravity of the crime committed.