STATE OF MADHYA PRADESH vs BHOLA @ BHAIRON PRASAD RAGHUVANSHI

The Supreme Court upheld the High Court's decision declaring Rule 3(a) of the Madhya Pradesh Prisoner’s Release on Probation Rules, 1964 as ultra vires Section 2 of the Madhya Pradesh Prisoner’s Release on Probation Act, 1954. The Court emphasized that the legislation aims to align with modern penal philosophy focused on rehabilitation rather than retribution. The appeal by the State of Madhya Pradesh was dismissed, and directions were issued to consider the prisoner's application for release on probation in accordance with the Act and Rules.