Avtar Singh vs State Of Haryana & Anr

The Supreme Court addressed the challenge to the constitutionality of sub-section (3) of Section 3 of the Haryana Good Conduct Prisoners (Temporary Release) Act, 1988, which states that the period of parole shall not count towards the actual sentence undergone. The Court referred to previous judgments in State of Haryana vs. Mohinder Singh and Sunil Fulchand Shah, which recognized that parole and furlough periods could be counted as part of the sentence, but noted that the validity of the specific sub-section had not been considered. Consequently, the matter was referred to a larger bench for further examination of its compliance with Articles 14 and 21 of the Constitution.