Multiple life terms cannot run one after another: SC

The Supreme Court changed how Koli’s two life sentences would operate. It set aside the direction that they run consecutively, meaning one after the other. The court left his convictions, fines and the remaining parts of the sentencing order intact.

Koli had received one life sentence for murdering a 12-year-old girl and another for rape. The trial court ordered consecutive sentences, and the Bombay high court upheld that direction in 2016. The Supreme Court applied the Constitution bench ruling in Muthuramalingam, which rejected consecutive life terms in a single trial.

The sentences must now be superimposed over each other. This does not cancel either sentence. Instead, each remains legally separate, so remission or commutation of one sentence does not automatically reduce or end the other. The ruling therefore corrected the method of serving the sentences without disturbing Koli’s convictions or fines.

Koli received two separate life sentences in the same trial. One was imposed for murder under Section 302 of the Indian Penal Code. The other was imposed for rape under Section 376. The case involved the 2010 rape and murder of a 12-year-old girl.

The Thane sessions court convicted him in 2013. It directed the two life terms to run consecutively, so one would follow the other. The Bombay high court upheld that arrangement in 2016. Koli challenged the consecutive-serving direction before the Supreme Court.

The Supreme Court confirmed that multiple life sentences can be awarded for separate offences. However, it ruled that life sentences cannot be directed to run consecutively. The murder sentence and the rape-related sentence, including wrongful confinement as stated in the ruling, must instead be superimposed. The court also maintained the fines and the rest of the sentencing order.

A consecutive sentence starts after the earlier sentence ends. For ordinary fixed terms, this can lengthen the total time in prison. A concurrent sentence runs alongside another sentence, so the terms overlap in operation. The Supreme Court said life sentences in this case cannot be made consecutive.

Superimposed life sentences also operate together, but they are not treated as one sentence. The court described this arrangement as different from directing sentences to run consecutively. Each life sentence remains attached to its particular offence, even though both are served over the same period.

That distinction matters if a competent authority grants remission or commutation. Relief affecting one superimposed sentence does not automatically provide relief for the other. In Koli’s case, the murder life sentence and the rape-related life sentence therefore remain separate legal sentences, while no longer being required to run one after another.

The Supreme Court relied on the Constitution bench decision in Muthuramalingam. That ruling explained that life imprisonment ordinarily extends to the remainder of a convict’s natural life, unless remission or commutation changes it. Requiring two such sentences to run consecutively would therefore create an anomaly.

The reason is simple: a person has only one life to live. A second life term cannot meaningfully begin after the first natural life has ended. The law can still recognise separate wrongdoing by awarding a separate life sentence for each offence. What it cannot do is make those life sentences run one after another.

The court therefore requires multiple life sentences to be superimposed. This preserves the separate legal consequences of each offence. It also ensures that remission or commutation of one sentence does not automatically extend to the other, as the Supreme Court reiterated while deciding Koli’s appeal.

When life sentences are superimposed, they operate together but do not merge into a single legal sentence. Each sentence continues to relate to its own offence. This preserves the separate consequences of convictions for different crimes, even though the sentences are not served one after another.

The Supreme Court specifically clarified that remission or commutation granted for one sentence would not automatically result in remission of the other. In Koli’s case, the life sentence for murder and the life sentence for rape and wrongful confinement therefore remain distinct. Relief affecting one does not automatically carry across.

The ruling creates a practical safeguard in sentencing. A competent authority may consider remission or commutation in respect of a particular sentence, but the other sentence is not automatically reduced with it. The court maintained both life terms while changing only their operation from consecutive to superimposed.

The article states that remission or commutation may be granted by the competent authority. That authority decides whether a life sentence is reduced, changed or otherwise relieved under the applicable process. The Supreme Court did not itself grant remission or commutation in Koli’s case.

The court’s role was narrower. It corrected the direction that Koli’s two life sentences should run consecutively. It ordered them to be superimposed, while preserving their separate legal status. This means any decision affecting one sentence does not automatically affect the other.

The source article does not identify which specific office or institution qualifies as the competent authority. It therefore supports only the general answer that the legally competent authority, rather than the sentencing direction alone, grants remission or commutation. The judgment’s key point is that such relief for one sentence cannot automatically extend to another separate life sentence.

The Constitution bench ruling cited by the Supreme Court said life imprisonment ordinarily extends to the remainder of a convict’s natural life. It is therefore different from a sentence stating a fixed number of years. A life sentence does not automatically end after a standard fixed term.

The article also explains that life imprisonment may change if the competent authority grants remission or commutation. Those powers can affect how the sentence operates. But when multiple life sentences are imposed, relief for one does not automatically extend to another if the sentences are superimposed.

This understanding shaped the decision in Koli’s case. The court said that making two life sentences consecutive would be anomalous because a person has only one life to live. It allowed both life sentences to stand, but required them to overlap. Thus, the sentences remain separate while their operation reflects the nature of life imprisonment.