Concurrent sentencing is discretionary under CrPC Section 31, while Article 142 may limit total imprisonment to secure complete justice.

Under Section 31 CrPC, concurrency of sentences for multiple convictions is a judicial discretion to be exercised on the facts of each case; absent an express direction, the sentences ordinarily run consecutively, and omission to specify the mode does not create a right to concurrency. The single transaction principle under Section 220 did not control the sentencing question on these facts. The Court also invoked Article 142 to mould the sentence in the interests of complete justice, limiting the total custodial term to 14 years while leaving the fine and default stipulations intact.

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Issues: (i) Whether, on the facts of the case, the sentences awarded for the multiple convictions were required to run concurrently or could be treated as consecutive under Section 31 of the Code of Criminal Procedure, 1973. (ii) Whether the sentence required modification under Article 142 of the Constitution of India so as to cap the total imprisonment at 14 years.

Issue (i): Whether, on the facts of the case, the sentences awarded for the multiple convictions were required to run concurrently or could be treated as consecutive under Section 31 of the Code of Criminal Procedure, 1973.

Analysis: Section 31(1) confers discretion on the court to direct concurrent running of sentences where a person is convicted at one trial of two or more offences. The discretion must be exercised judicially having regard to the nature of the offences and the attendant circumstances. Where the court does not direct concurrency, the sentences ordinarily run consecutively, and the omission to specify the sequence does not by itself create a right to concurrency. The single transaction principle under Section 220 does not control the sentencing question in the present facts.

Conclusion: The sentences could not be treated as concurrent merely because the trial court and the High Court failed to state the mode of running; the default position of consecutive running applied, subject to the later modification ordered by the Court.

Issue (ii): Whether the sentence required modification under Article 142 of the Constitution of India so as to cap the total imprisonment at 14 years.

Analysis: The offences were committed in 2008, the appellants had already undergone more than 13 years of imprisonment, and the record did not show any adverse conduct during custody. Balancing the requirements of punishment with the need for a reasonable release period, and keeping in view the overall sentencing scheme, the Court found that complete justice would be met by limiting the maximum imprisonment to 14 years.

Conclusion: The punishment was modified so that the total imprisonment to be served would not exceed 14 years, while the fine and default stipulations were left intact.

Final Conclusion: The appeal succeeded in part: the Court declined to accept the plea for concurrency as a matter of right, but exercised its constitutional power to reduce the effective custodial exposure and to confine imprisonment to 14 years.

Ratio Decidendi: Under Section 31 of the Code of Criminal Procedure, 1973, concurrency of multiple sentences is a matter of judicial discretion to be exercised on the facts of each case, and absent a direction of concurrency the sentences run consecutively; however, in an appropriate case, Article 142 of the Constitution of India may be invoked to mould the sentence to secure complete justice.

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