Supreme Court Pulls Up Odisha Sentence Review Board Over Delay in Dara Singh’s Remission Plea

The Supreme Court on Wednesday expressed strong displeasure with the Odisha State Sentence Review Board for its continued failure to decide the premature release plea of Ravindra Pal alias Dara Singh, who is serving a life sentence for the 1999 murder of Australian missionary Graham Staines and his two minor sons. The bench of Justices Manoj Misra and Vijay Bishnoi gave the board a final opportunity to take a decision by September 2, warning that if no action is taken, the Court would step in.

“You take a decision whatever you want to. Otherwise we will take our own. If you don’t take a decision, we will,” the bench told the state’s counsel, adding, “We can’t tolerate this avoiding taking a decision.” The Court noted that Singh has been incarcerated for more than 26 years, and the matter had been adjourned multiple times to allow the board to deliberate.

Court’s Frustration Boils Over

During the hearing, the Odisha government attempted to justify the delay by placing before the Court a letter from the Directorate of Prisons and Correctional Services, stating that a report from the Keonjhar District Jail was still awaited. The bench was unimpressed. “We are not informed about the decision of the Sentence Review Board,” the Court observed, and asked, “How is it relevant? It is the board which has to take a decision.”

The Court made it clear that administrative communication between state departments was not an acceptable excuse. “We are not concerned about how you are communicating, to what authority you are communicating. You just take a decision,” the bench remarked. The matter was adjourned to September 2, with a directive that the Sentence Review Board must apprise the Court of its decision by then.

Background of the Notorious Crime

The case dates back to the night of January 22, 1999, when a mob led by Dara Singh trapped Graham Staines and his two sons, Philip (aged 10) and Timothy (aged 6), inside their station wagon in Manoharpur village, Keonjhar district, and set the vehicle ablaze. Staines and his wife Gladys worked with the Mayurbhanj Evangelical Missionary, providing care for leprosy patients. Gladys Staines, who later received the Padma Shri, publicly forgave the killers and continued her humanitarian work in India.

A special CBI court convicted Singh and sentenced him to death in 2003. The Orissa High Court commuted the death sentence to life imprisonment in 2005, a decision upheld by the Supreme Court in 2011. The Supreme Court’s original judgment had referred to an intention to “teach a lesson” to Staines for his religious activities, but those remarks were later modified after criticism, with the Court stating that “there is no justification for interfering in someone’s religious belief by any means.”

A Lingering Decision

Dara Singh, now over 60 years old, filed a writ petition before the Supreme Court seeking direction to the Odisha government to consider his premature release under the state’s Guideline for Premature Release 2022. He claimed that he has served more than 26 years in prison without any remission or parole, and expressed regret for his actions, describing them as committed in a fit of “youthful rage.” He also cited the reformative theory of punishment and referred to the Supreme Court’s 2022 judgment allowing premature release of the convicts in the Rajiv Gandhi assassination case.

Under Odisha’s remission policy, life convicts whose death sentences have been commuted may be considered for remission after completing 25 years of incarceration, though such release is not automatic. The Sentence Review Board had reportedly considered Singh’s case in its July 2025 meeting and even recommended his release based on good conduct, but the recommendation remained pending final approval.

Legal Implications and Precedent

The Supreme Court’s intervention underscores the constitutional right to a timely decision on remission, which is an integral facet of the right to life and personal liberty under Article 21 of the Constitution. The Court’s reluctance to accept bureaucratic delays signals that executive inaction cannot indefinitely deprive a convict of the opportunity to be considered for release, especially when the state’s own policy prescribes a framework.

Legal experts view this as a significant reminder to state governments and sentence review boards that the judiciary will not hesitate to enforce accountability. The case also highlights the tension between the state’s discretion in remission matters and the judiciary’s power to ensure that discretion is not exercised arbitrarily or with undue delay.

What Lies Ahead

With the next hearing fixed for September 2, all eyes are on the Odisha Sentence Review Board. If no decision is announced by then, the Supreme Court may exercise its own authority to direct the release or lay down specific conditions for Singh’s premature release. Given the high-profile nature of the case and the strong language used by the bench, the state is likely to expedite the process.

For legal professionals, this development serves as a crucial illustration of judicial oversight over executive functions in the context of criminal justice administration. It also reiterates that the reformative aspect of punishment—recognized under Article 72 and Article 161 of the Constitution through the power of clemency—cannot be undermined by administrative inertia.

As the September deadline approaches, the legal community awaits a decision that could set a precedent for countless other life convicts waiting for their remission pleas to be processed in a timely manner.