Delhi High Court Questions Sentencing Review Board in Mattoo Case

Criticism of the Sentencing Review Board

The Delhi High Court recently expressed discontent with the Sentencing Review Board’s (SRB) decision to deny Santosh Kumar Singh’s application for premature release. Justice Anup J Bhambhani remarked that the SRB appeared to be basing its decisions on public sentiment rather than objective standards. He commented that the board’s approach resembled that of a blindfolded Lady Justice, stating, “Your name doesn’t sound good, so I am rejecting it.”

Santosh Kumar Singh was convicted in 1996 for the rape and murder of Delhi University law student, Priyadarshini Mattoo. Despite a lower court acquitting him in 1999 due to insufficient evidence, the Delhi High Court imposed a death sentence on him in 2006. The Supreme Court later commuted the death penalty to life imprisonment in 2010.

Having spent nearly three decades in custody, Singh’s plea for premature release was rejected by the SRB for the second time. The High Court had previously overturned the first rejection in July 2025 and ordered a fresh review. The latest hearing is scheduled for April 20, where it will be grouped with other cases where the SRB similarly declined release requests.

Understanding Premature Release

Premature release is a legal provision that permits life convicts to be released early if they are deemed reformed, rehabilitated, and not a threat to society. This authority is derived from the Indian Constitution, specifically Articles 72 and 161, which grant the President and state Governors the power to provide remission in eligible cases. Further, the Bharatiya Nagarik Suraksha Sanhita (BNSS) outlines additional criteria, with a minimum requirement of 14 years of actual imprisonment before such consideration can occur, particularly in cases where death was a potential sentence.

However, eligibility does not ensure favorable consideration. The SRB, which consists of senior officials including the Director General of Prisons and police commissioners, is responsible for evaluating cases before forwarding recommendations to the government. Advocate-on-Record RHA Sikander highlighted that factors such as good conduct and jail behavior are critical in determining eligibility, emphasizing the importance of compliance with parole terms.

The Supreme Court clarified in a 2015 ruling concerning remission that the process is not an unchecked executive function and requires judicial consultation and justification based on various factors. The nature and severity of the crime cannot be the sole basis for denying remission.

Details from the SRB’s Report

In its November 2025 ruling, the SRB justified its decision based on a police report characterizing Singh’s crime as heinous, suggesting that his release could disrupt public peace and stability. The board also noted that family members of the victim and various public figures had opposed Singh’s release. The SRB deemed that the premeditated nature of the crime warranted a rejection of the release request.

The High Court found the SRB’s rationale unsatisfactory, with Advocate RHA Sikander arguing that the claim about public tranquility was speculative and could have been addressed through imposition of conditions. Justice Bhambhani reiterated the importance of rehabilitation, pointing out that individuals with extended custodial sentences deserve consideration based on their behavior.

Comparative Cases

Previous cases with significant public exposure have seen favorable rulings for release. Manu Sharma, convicted in the Jessica Lall murder case, secured premature release in 2020 after more than two decades of imprisonment. Similarly, Sushil Sharma, convicted for the 1995 Tandoor murder, was released in 2018 following the High Court’s intervention after his application was initially denied by the SRB.

The Supreme Court ruled in the Nitish Katara murder case that no SRB sanction was necessary for the release of a co-convict following completion of their fixed sentence. This highlights a growing judicial sentiment against SRB’s broader denial of remission requests based on public reaction or the severity of crimes.

Examining the Pattern

The Mattoo case illustrates a larger pattern in remission appeals, where the SRB tends to err on the side of caution in high-profile cases. Advocate Sikander noted that this cautious stance stems from institutional concerns affecting the perception of such decisions, often leading to judicial intervention for reconsideration or review.

This cycle of rejection by the SRB followed by court appeals has become a recurring theme in the legal landscape, emphasizing the tension between public sentiment and the principles governing convict rehabilitation.