Sanjay vs State Of M.P

The Supreme Court held that under Section 21 of the Narcotic Drugs and Psychotropic Substances Act, 1985, the appellants, convicted for possession of 12 gms of contraband, did not warrant the maximum punishment due to their prolonged custody of over eight years. The Court applied the doctrine of proportionality, concluding that reducing the sentence to the period already undergone would serve the interests of justice. Consequently, the appeals were allowed and the appellants were directed to be released immediately.