Wednesday, 12 August 2026

Supreme Court: Courts Should Adopt Liberal Approach In Condoning Delay In Appeals Filed By Convicts from jail

We are deeply dismayed, and equally perturbed by the

order which rejected an application seeking condonation of delay

of 3157 days and as a consequence dismissed the ‘Jail Memo of

Appeal’ against the order of conviction under Section 302, with

sentence imposed of life imprisonment where the convict had, at

the time of the impugned order suffered incarceration of 12 years

and now a further period of 10 years; a total of 22 years. {Para 2}

3. Access to justice still eludes the marginalized sections of our

society and especially those convicted and imprisoned from

amongst them. When the three pillars of democracy consistently

endeavor to bring legal aid to the doorsteps of every citizen,

especially the poor, the needy and the deprived, we, in the

Constitutional Courts should introspect to sensitize ourselves in

taking a liberal approach insofar as delay occasioned in filing an

appeal from an order of conviction and sentence, depriving a

person, the most valuable and fundamental of all rights; liberty.

Not a mere liberal approach but a pro-active one to condone

delay, however large it is when a convict knocks at the door of a

Court, in appeal, which in the present case raises some real

concerns. 

Reportable

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

Criminal Appeal No…………..of 2026

(@Special Leave Petition (Crl.) No.7128 of 2026)

Arjun Jani @ Tuntun Vs   State of Orissa

Author: K. VINOD CHANDRAN, J.

Citation: 2026 INSC 802

Dated: AUGUST 04, 2026.

Leave granted.

2. We are deeply dismayed, and equally perturbed by the

order which rejected an application seeking condonation of delay

of 3157 days and as a consequence dismissed the ‘Jail Memo of

Appeal’ against the order of conviction under Section 302, with

sentence imposed of life imprisonment where the convict had, at

the time of the impugned order suffered incarceration of 12 years

and now a further period of 10 years; a total of 22 years.

3. Access to justice still eludes the marginalized sections of our

society and especially those convicted and imprisoned from

amongst them. When the three pillars of democracy consistently

endeavor to bring legal aid to the doorsteps of every citizen,

especially the poor, the needy and the deprived, we, in the

Constitutional Courts should introspect to sensitize ourselves in

taking a liberal approach insofar as delay occasioned in filing an

appeal from an order of conviction and sentence, depriving a

person, the most valuable and fundamental of all rights; liberty.

Not a mere liberal approach but a pro-active one to condone

delay, however large it is when a convict knocks at the door of a

Court, in appeal, which in the present case raises some real

concerns.

4. The above appeal filed with assistance from the legal

services, after undergoing 22 years in prison, is filed with a delay

of 3703 days, which has already been condoned by a Coordinate

Bench. The Coordinate Bench, in which one of us,

(J. B. Pardiwala, J.) was a member, by order dated 07.05.2026,

termed the impugned order to be very disturbing and noticed

thus: -

“7. The High Court, while declining to condone the

delay, ought to have considered the fact that the

petitioner was already undergoing sentence past 12

years. The High Court ought to have also considered

that it was an appeal through jail. This itself was

sufficient for the High Court to take a practical view

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or rather a sympathetic view of the matter and at least

ought to have condoned the delay so as to give one

opportunity to the petitioner to argue his criminal

appeal on merits. As on date, the petitioner has

undergone almost 22 years of sentence.”

5. The Conduct Certificate issued by the jail authorities

certified that during the period of confinement the conduct and

behavior of the appellant was satisfactory, he maintained good

relationship with co-prisoners and was at no time punished for

any jail offence. The Coordinate Bench released the appellant on

bail on his execution of personal bond of Rs.10,000/- to the

satisfaction of the Jail Superintendent. The District Legal Services

Authority, Koraput, State of Odisha was also directed to prepare

an appropriate representation, seeking remission of sentence in

accordance with the remission policy prevailing at the time of the

commission of offence or any beneficial policy thereafter.

6. On the last date of hearing, since the case revealed the

murder of three women, which information led to the initiation of

criminal prosecution, we were apprehensive of whether the

deaths were the result of a psychological aberration. We hence

summoned the Station House Officer (SHO) of the jurisdictional

Police Station so as to understand whether there were any serial

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killings of like nature reported during the time when the instant

murders were brought to light, especially when the women were

alleged to have been killed with stones, smashing their heads in

a public road. The SHO was present today and he informed us that

on examination of records, there was no like incident reported at

the time when the subject incident came to light.

7. The learned Counsel appearing for the State referred to

Annexure P4, in answer to a query regarding the remission

policy. It is seen from Annexure P4 that the application of the

appellant for remission was rejected six times, the last of which

was on 19.09.2025. The order noticed that after 22 years of actual

imprisonment, he is 45 years of age and with remission he would

have undergone 25 years of incarceration. It is specifically

recorded that “It is submitted here that both the Policy for the year

2000 and the current Policy (2022) are beneficial to the Petitioner

with regard to his Premature Release”. However, the Deputy I.G.

of Prisons lamented that as per Clause 6(4) of Law Department

Resolution dated 26.09.2000 as well as Clause 8(4) of the current

Policy, the case of the petitioner will be reconsidered by the State

Sentencing Review Board (SSRB) only after expiry of one year

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from the date of last consideration. The lament falls on deaf ears,

and the prior rejections were also due to apprehension of law and

order situation arising since the people of the locality were

against his release; which in every circumstance cannot be a

cause, not to judiciously exercise the power of remission.

8. Be that as it may, we looked into the merits of the matter and

from the testimonies we see a pall of incredulity. Before we

examine the evidence, we have to notice that the scene of

occurrence, as discernible from the depositions, was a locality;

with cluttered houses, no electricity, a factory nearby which

operates with deafening sound and inhabited by people from the

marginalized sections. The deceased were numbered three and

named Kamala, Sonbari & Ratanai, residing in the place, in

separate houses. The witnesses too were neighboring residents.

9. PW3, the eyewitness spoke of having seen the accused

striking the head of Ratanai residing in the locality and tried to

intercede but when threatened by the accused, fled in fear to the

house of PW4. There is no clarity as to whether she informed the

gruesome incident she witnessed, immediately to PW4 or not.

Next day morning, PW3 on returning to her house found some

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villagers gathered at the alleged scene of crime. PW7 says that

she went to a tea shop in the morning nearby, recited the incident

and together with others came back to the crime scene. She then

found, the bodies of Kamala and Sonbari lying at the scene of

occurrence, for the first time and was then made aware of two

other deaths having occurred on the same night, all of them

women. PW3 in cross examination admitted that her husband was

in the house on that night and later, said that he had gone out after

dinner.

10. The prosecution went to trial with the eyewitness testimony

and the corroboration by way of res gestae, as coming out from

PWs 1 to 4 & 7, who have different versions as to how they came

to hear the version of PW3 about the incident. In cross

examination it was deposed that she witnessed the assault from

within her house, peeping through a gap in the door at 1o’ clock

in the night. The Investigating Officer (I.O.) denied the testimony

of PW3 that she spoke of the occurrence to PW2, having been

stated to him at the time of investigation. The testimony of PW4

that PW2 was trembling out of fear and she slept in her house also

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was not recorded in her statement under Section 161 of the Code

of Criminal Procedure, 1973 (Cr. PC).

11. There was an earlier incident deposed to, by PW3

corroborated by PWs 2,4, 7 & 9 of the accused, having roamed the

streets screaming that he wanted to ‘kill someone’; with no name

disclosed. PW3 also stated that the accused walked into her

house, took a tumbler and later went to Kamala’s house (one of the

deceased) with liquor. More shocking is the statement of PW3 that

from her house to go to PW4’s house she has to pass Kamala’s

house, in front of which the two other bodies were seen. This has

to be juxtaposed with the fact that PW3 witnesses the murder of

only Ratanai and not the others and while she was fleeing at night

she did not see the other dead bodies lying on her way to PW4’s

house.

12. Relevant is also the fact that the I.O, PW13, who also carried

out the inquest has not spoken of the scene of occurrence nor

prepared a sketch, especially when three bodies of murdered

victims were recovered. It is pertinent that PW13 does not have

any explanation as to how he reached the accused and arrested

him. But he speaks of a confession having been made by the

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accused after his arrest which definitely cannot be relied upon;

inadmissible under Section 25 of the Indian Evidence Act, 1872.

Very significantly PW8, one of the witnesses of the recovery

under Section 27, speaks of the police having beat the accused to

extract the confession.

13. The recovery of MOI to MOIII; stones and a brick, from the

accused, as spoken of by the I.O. was specifically rejected by the

trial court, rightly so since there was nothing found in the stones

recovered, connecting those to the murder. No blood stains were

visibly seen, as deposed by the I.O, nor were any detected, on

chemical examination at the Forensic Science Laboratory, which

report though produced no positive result was spoken of by the

I.O. Again, while the I.O spoke of the recovery of MoI to MOIII

from the bushes near the scene of crime, as pointed out by the

accused, PW1, the First Informant, PW3, the eyewitness, PW8 and

PW9, the mahazar witnesses of the recovery, consistently said that

MOI to MOIII were lying near the bodies, in plain view and with

blood stains.

14. The eyewitness testimony alone resulted in the conviction of

the accused, which is not impermissible, but only when the

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testimony is believable, credible, consistent with the other

circumstances and inspires the confidence of the Court and not

when there are serious discrepancies raising a reasonable doubt

as to the witnessing of the incident.

15. PW3 speaks of having known the accused and the deceased

women and testified that at about 8/9 pm on the ill-fated night, the

accused was shouting ‘to kill somebody’. He is said to have gone

to her house and picked up a pot, when her husband was present.

At midnight, she got up hearing a sound and through a gap in the

door, witnessed one murder after which she fled. She did not

speak of the other murders, though PW7, who met her at the Tea

Shop, next day morning, speaks of PW3 having told him about

three murders, first Kamala, then Sonbari and lastly, Ratanai. PW4

did not ask why PW3 came to her house in the midnight despite

finding her to be trembling with fear. None were awakened in the

night despite three murders having occurred at night. The three

bodies were strewn around at the scene without any explanation

as to why the victims came out of the house in the dead of the

night. None of the relatives or co-inhabitants of the deceased

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were examined, nor was it brought out that they were residing

alone.

16. The result of the postmortem examination conducted by

PW5 as per his testimony reveals almost similar injuries having

been caused on the three women, on their face and on the head,

with heavy blunt object. They died of internal bleeding and brain

injury.

17. As we found, the testimony of the eyewitness is shaky and

highly improbable, it does not lead to a definite conclusion that

the accused murdered the three women. In any event, though the

accused was alleged with three murders, he has been convicted

for only one, of that witnessed by PW3. We are of the opinion that

the prosecution leaves a lot to be desired and there lingers a

serious doubt in our minds as to the finding of guilt entered by the

trial court on the sole testimony of the eyewitness, which in the

given circumstances is found to be highly improbable. We hence

set aside the judgment of the trial court and acquit the accused.

As we noticed, the accused was released on a personal bond of

Rs.10,000/-, which shall stand cancelled.

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18. Three lives were snuffed out, having been bludgeoned to

death, a person taken into custody on mere suspicion from whom

a confession; though not admissible was extracted employing

third-degree methods, the trial court fails to evaluate the

evidence properly and the High Court remains a moot spectator

while adding to the tally of disposals; cumulatively resulting in 22

years being erased out of a person’s life without any reliable

evidence.

19. We deem it appropriate to direct the District Legal Services

Authority, Koraput, State of Odisha to attempt rehabilitation or

resettlement of the appellant for which the District Administration,

headed by the District Collector shall assist.

20. The appeal stands allowed with the above directions.

21. Pending applications, if any, shall also stand disposed of.

.……………………………... J.

(J. B. PARDIWALA)

..………….…………………. J.

(K. VINOD CHANDRAN)

NEW DELHI;

AUGUST 04, 2026.

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