Ajay Kumar Pal vs Union Of India And Anr

The Supreme Court held that the inordinate delay of 3 years and 10 months in the disposal of the petitioner's Mercy Petition, along with the conditions of solitary confinement, warranted the commutation of the death sentence to life imprisonment under Article 21 of the Constitution. The Court relied on its earlier decision in Shatrughan Chauhan v. Union of India, affirming that such delays can constitute a supervening circumstance justifying relief. Consequently, the Court granted the petitioner's request for commutation.