Delhi Administration (Now N.C.T. Of ... vs Manohar Lal

The Supreme Court held that the High Court exceeded its jurisdiction under Section 433(d) of the Criminal Procedure Code by ordering commutation of the respondent's sentence for food adulteration without the State Government's discretion. The Court emphasized that the power to commute sentences lies solely with the State Government and not with the High Court, especially in cases involving social evils like food adulteration, which mandates minimum sentences. Consequently, the Supreme Court set aside the High Court's order and reinstated the original sentence imposed by the trial court.