In a significant relief to a life convict from Odisha, the Supreme Court of India has suspended his life sentence after noting that he had already spent more than 11 years in prison while his appeal remained unheard before the High Court.
A Bench of Justice Dipankar Datta and Justice Satish Chandra Sharma passed the order in the case of Muna Bisoi vs State of Odisha on February 16, 2026.
Background of the Case
Muna Bisoi was convicted by a Sessions Court for murder under Section 302 read with Section 34 of the Indian Penal Code, along with an offence under Section 27 of the Arms Act. He was sentenced to life imprisonment.
Challenging his conviction, Bisoi filed a criminal appeal before the Orissa High Court in 2016. However, nearly a decade later, the appeal is still pending.
When his plea for suspension of sentence came up before the High Court in October 2025, the court declined to suspend the life sentence but granted him interim bail for three months. The bail period was set to expire on January 22, 2026.
Just before the expiry of that interim relief, Bisoi approached the Supreme Court.
What Happened in the Supreme Court
The Supreme Court initially extended his interim bail in January 2026. When the matter was taken up for final consideration, the Bench closely examined the long delay in hearing the appeal.
The judges noted that Bisoi had already spent over a decade in jail while waiting for his appeal to be heard.
“It does not surprise us any longer that despite the appeal having been filed in 2016, the High Court could not find time to hear it,” the Bench remarked, pointing to the prolonged incarceration .
At the same time, the Court acknowledged that the High Court may have had genuine constraints. Still, it emphasized that the right to appeal is a legal right under Section 374(2) of the Code of Criminal Procedure.
The Bench cautioned that “serious failure of justice could ensue” if a person remains in jail for years and later succeeds in appeal .
Reliance on Kashmira Singh Judgment
The Court relied heavily on its earlier landmark ruling in Kashmira Singh vs. State of Punjab, decided nearly five decades ago.
In that judgment, the Supreme Court had questioned the practice of routinely denying bail to life convicts during the pendency of appeals. The earlier Bench had observed that no court practice can continue if it results in injustice.
Quoting from that decision, the present Bench recalled that it would be a “travesty of justice” to keep someone in jail for five or six years if the court is unable to hear the appeal in time and the person is later found innocent .
The earlier ruling had stressed that if appeals cannot be heard within a reasonable time, courts should ordinarily grant bail unless there are strong reasons to refuse.
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Court’s Observations on Delay
The Supreme Court made it clear that there was nothing on record to suggest that the delay in hearing the appeal was caused by Bisoi.
Keeping this in mind, and applying the principles laid down in the Kashmira Singh case, the Court decided to intervene.
The Bench said it was “inclined to allow the appeal by suspending the sentence of life imprisonment” imposed on Bisoi and to make the interim bail order absolute .
The Decision
The Supreme Court set aside the High Court’s October 2025 order to the extent it refused suspension of sentence.
Bisoi will now continue to remain on bail until the High Court passes further orders.
Importantly, the Supreme Court requested the Orissa High Court to decide the pending criminal appeal as early as possible, preferably within six months from receiving a copy of the order.
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The Court also clarified that if the appellant fails to actively pursue his appeal, the High Court may appoint an amicus curiae (a lawyer assisting the court) and decide the case on its merits.
With these directions, the appeal was allowed and pending applications were disposed of.
Case Title: Muna Bisoi vs State of Odisha
Case No.: Criminal Appeal (arising out of SLP (Crl.) Diary No. 163 of 2026)
Decision Date: February 16, 2026
