Supreme Court Holds that imprisonment term commencing after a life sentence is unreasonable

In the criminal Special Leave Petition No. 5183 of 2021, in the case of Imran Jalal Bilal Ahmed v. State of Karnataka , heard by the bench of Justices U.U. Lalit, Hemant Gupta and S. Ravindra Bhat, the Supreme Court quashed a sentence of 10 ten years of rigorous imprisonment under Section 5(b) of Explosive Substances Act, 1908, which was to commence after the life imprisonment.


This appeal was granted from the sentence of the High Court of Karnataka pronounced by the High Court on November 29, 2019. On 5th January, 2007, Imran Jalal was apprehended in a Bengaluru bus with his bags containing AK assault rifle, packets of ammunition, satellite phone, hand grenades and Bengaluru city map.

The accused was convicted under Section 121 of IPC (waging war against Government of India), 121A of IPC (conspiracy to commit crime under Section 121), Section 122 of IPC (collecting arms with intention of waging war), and a sentence of life imprisonment under Section 20 (punishment for being member of terrorist organisation) of Unlawful Activities (Prevention) Act, 1967.


The Supreme Court followed Muthuramalingam v. State (2016) 8 SCC 313, where it had held that “if the court directs the life sentence to start first it would necessarily imply that the term sentence would run concurrently ”, and no further consecutive term sentence could be imposed, for the sentence of life imprisonment means incarceration for the normal life of a convict.

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