One Life, Not Two: Supreme Court Reaffirms the Impossibility of Consecutive Life Sentences in Raju Shantaram Koli

A doctrinal examination of 2026 INSC 1161 and the enduring authority of Muthuramalingam

Introduction

The question whether a convict can be directed to undergo imprisonment for life more than once has long been settled in principle, yet continues to surface in sentencing practice. On 27 October 2026, the Supreme Court in Raju Shantaram Koli v. The State of Maharashtra (2026 INSC 1161) once again confronted this issue and answered it with clarity and restraint.

A Bench comprising Justice K.V. Viswanathan and Justice Arun Palli held that life sentences imposed for distinct offences in a single trial cannot be ordered to run consecutively. They must, instead, be superimposed upon each other. The decision does not innovate. It reaffirms, with precision, the Constitution Bench ruling in Muthuramalingam v. State (2016) 8 SCC 313.

Factual Matrix

The appellant stood convicted by the Additional Sessions Judge, Thane, for the rape and murder of a twelve-year-old girl. He was sentenced to imprisonment for life under Section 302 of the Indian Penal Code and to a further term of imprisonment for life under Section 376 read with Section 342. The Trial Court directed that the two life sentences would run consecutively. The Bombay High Court affirmed the conviction and the consecutive nature of the sentences. The limited challenge before the Supreme Court was confined to the direction regarding consecutive running of the life sentences.

The Holding

The Supreme Court held:

• Multiple life sentences awarded in a single trial cannot be directed to run consecutively.
• Such sentences shall stand superimposed over each other.
• The purpose of superimposition is to ensure that any remission or commutation granted by the competent authority in respect of one life sentence does not, by itself, result in the remission of the other.
• The direction of the Trial Court and the High Court ordering consecutive operation of the two life sentences was set aside.
• The remainder of the conviction, the sentences of fine, the default sentences, and the benefit of set-off under Section 428 of the Code of Criminal Procedure were left undisturbed.

Doctrinal Foundation: The Muthuramalingam Principle

The judgment rests squarely on the Constitution Bench decision in Muthuramalingam. That Bench had observed that any direction requiring an offender to undergo imprisonment for life twice over would be anomalous and irrational, for it would disregard the elementary truth that a human being has but one life.

The present Bench has neither diluted nor expanded that principle. It has applied it with fidelity. The Court has reiterated that while multiple life sentences may lawfully be imposed, the mode of their operation must remain consistent with the nature of life imprisonment itself.

Superimposition and the Protection of Distinct Sentences

The real practical significance of the decision lies in the distinction between consecutivity and superimposition.

A direction that life sentences shall run consecutively creates a legal fiction: that after the prisoner has served one life term (or obtained remission thereof), he must begin serving another. Superimposition avoids this fiction. Both sentences operate simultaneously. Remission or commutation granted in respect of one does not automatically extinguish or reduce the other. Each sentence retains its independent vitality and must be considered separately by the competent authority.

This approach preserves the punitive integrity of each conviction while remaining faithful to the biological and legal reality that a person possesses only one life.

Analytical Appraisal

The judgment is marked by restraint. It does not open new doctrinal ground. It simply declines to permit lower courts to ignore a clear Constitution Bench precedent that has stood for a decade.

That such directions continue to be passed even after Muthuramalingam reveals a persistent gap between settled principle and sentencing practice. The present decision serves as a necessary corrective. It reminds courts that sentencing power, however wide, remains bounded by reason and by the fundamental character of the punishment of life imprisonment.

At the same time, the Court has carefully protected the interests of justice. By directing superimposition rather than concurrency in the ordinary sense, it has ensured that the second life sentence does not lose its force merely because remission is granted in the first. The balance struck is both humane and principled.

Conclusion

Raju Shantaram Koli is not a radical judgment. It is a clarifying one.

It reaffirms that the law does not deal in impossibilities. A direction to serve life imprisonment twice over is not merely incorrect; it is conceptually incoherent. By insisting upon superimposition, the Supreme Court has restored doctrinal coherence and prevented an irrational application of sentencing discretion.

In doing so, the Court has once again demonstrated that while the criminal law may be severe, it need not be absurd.