On June 11, 2025, the Delhi High Court delivered a significant verdict directing reform in how the Sentence Review Board (SRB) functions regarding premature release of prisoners. The Court expressed concern over members of the SRB not attending meetings personally and merely sending representatives, reducing the seriousness of the review process.
Justice Girish Kathpalia, while hearing the case of life convict Vikram Yadav, highlighted how SRB meeting records from 2020 to 2023 showed a “copy-paste” approach in rejecting applications. The Court observed that such mechanical decisions defeat the purpose of reformation in criminal justice.
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“The SRB deals with human beings… The approach of the SRB ought to be reformation oriented and not a routine disposal/statistics dominated exercise.”
The Court was reviewing Vikram Yadav’s case, who has served over 21 years in jail (including remission) for his conviction under multiple IPC sections. His applications were consistently rejected, mostly citing his past parole jump in 2010 and the seriousness of the crime. However, he was later acquitted in the two cases for which he was re-arrested in 2015.
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The Court strongly criticized the current composition of the SRB. It noted that members such as the Minister, Principal Secretary (Home), and Law Secretary often cannot deeply evaluate individual reform progress. Thus, the Court suggested including:
- The original sentencing judicial officer or successor.
- An eminent sociologist and criminologist with a reformation-centric outlook.
- The jail superintendent familiar with the convict’s behaviour.
“The composition of SRB should be based on the nexus between the jail performance of the prisoner and the job profile of the member… not just high official designation.”
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Regarding the decision-making process, the Court emphasized that a mere ‘yes or no’ binary cannot serve justice. It advised SRB to:
- Prepare a comparative list of aggravating and mitigating factors.
- Consider gradual release, moving the convict to semi-open or open prisons.
- Include conditions like police reporting for those granted premature release.
“That gradual movement would give a taste of liberty to the prisoner, which would encourage him to push for his reformation.”
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Vikram Yadav presented commendation certificates, participation in jail programs, and clean conduct post-2015. The Court noted these indicators of personal reform and stated they must not be overlooked.
On police objections to Yadav's release, the Court remarked that such objections must be reasoned and not routine.
“Not everything propounded for an accused or a convict has to be opposed by police as a matter of routine.”
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Although the Court did not immediately order Yadav's release, it instructed the SRB to reconsider his case under the 2004 remission policy and complete the process within four weeks.
“The decision of SRB shall be worded in a manner that one can decipher as to what worked in the mind of SRB.”
Case title: Vikram Yadav v. State Govt of NCT of Delhi
Case no.: W.P.(CRL) 3429/2024
