Life imprisonment and consecutive sentencing: multiple life terms cannot run one after another, but term sentences may precede them.

Section 31 CrPC was interpreted consistently with the settled meaning of life imprisonment: imprisonment for life means imprisonment for the remainder of the convict's natural life unless lawfully remitted or commuted. On that basis, multiple life sentences may be awarded at one trial for several murders, but they cannot be directed to run consecutively; they operate concurrently. The Court also distinguished term sentences from life imprisonment and held that a term sentence may be directed to run consecutively before the life sentence commences, since the sequence of sentences can be fixed under Section 31.

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Issues: (i) Whether multiple sentences of imprisonment for life awarded at one trial for several murders can be directed to run consecutively; (ii) Whether term sentences may be directed to run consecutively with a sentence of imprisonment for life.

Issue (i): Whether multiple sentences of imprisonment for life awarded at one trial for several murders can be directed to run consecutively.

Analysis: Section 31 of the Code of Criminal Procedure, 1973 permits consecutive running of sentences awarded at one trial, but the provision must be construed consistently with the settled meaning of life imprisonment. Life imprisonment means imprisonment for the remainder of the convict's natural life unless lawfully remitted or commuted. A direction making a convict undergo more than one life sentence one after another is anomalous because a person has only one life span. Earlier views treating consecutive life sentences as permissible were held not to state the law correctly to that extent.

Conclusion: Multiple life sentences may be awarded, but they cannot be directed to run consecutively; they operate concurrently by being superimposed upon each other.

Issue (ii): Whether term sentences may be directed to run consecutively with a sentence of imprisonment for life.

Analysis: The power under Section 31 of the Code of Criminal Procedure, 1973 includes determining the order in which sentences will run. A term sentence may validly be ordered to run before the commencement of a life sentence. The converse is not workable because once life imprisonment begins, no further sentence can meaningfully be served thereafter. The Court thus distinguished term sentences from multiple life sentences.

Conclusion: Term sentences may be directed to run consecutively before the life sentence commences.

Final Conclusion: Consecutive life sentences are impermissible, but the Court may direct term sentences to be served in sequence before the life sentence, leaving the remaining issue to the regular Bench.

Ratio Decidendi: Life imprisonment means imprisonment for the remainder of the convict's natural life, so multiple life sentences at one trial cannot be made to run consecutively, though term sentences may be sequenced before commencement of the life sentence.

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