Name of the Case: SUKHDEV YADAV @ PEHALWAN VS. STATE OF (NCT OF DELHI) & OTHERS
Citation: 2025 INSC 969
Hon’ble Bench: JUSTICE B.V. NAGARATHNA AND K.V. VISWANATHAN
Date: 29.07.2025
The Hon’ble Supreme Court held that when a High Court or the Supreme Court imposes a fixed-term life sentence, such as life imprisonment for 20 years without remission, the convict is entitled to automatic release upon completing that exact period of actual imprisonment. In such cases, the requirement to apply for remission to a Sentence Review Board does not arise, since the sentence is not an open-ended life term subject to executive discretion but a judicially determined fixed duration.
The Hon’ble Court emphasised that keeping a person in custody beyond the judicially fixed term violates Article 21 of the Constitution and amounts to illegal detention. Once the fixed period ends, the convict’s debt to society is discharged, and no further authorisation from the executive is necessary. The Sentence Review Board cannot override or re-evaluate a sentence that has already been expressly determined and affirmed by the highest court.
