In a significant order highlighting the impact of judicial delay, the Supreme Court on February 16, 2026, granted relief to a murder convict from Odisha who has spent over eleven years in prison while his appeal remained unheard.
A Bench of Justice Dipankar Datta and Justice Satish Chandra Sharma suspended the life sentence of Muna Bisoi, observing that prolonged incarceration during a pending appeal could result in serious injustice.
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Background of the Case
Muna Bisoi was convicted by a Sessions Court under Sections 302/34 of the Indian Penal Code (murder with common intention) and Section 27 of the Arms Act. He was sentenced to life imprisonment .
He challenged his conviction before the Orissa High Court in 2016. However, the appeal has not yet been decided.
In October 2025, the High Court declined his plea for suspension of sentence but granted him interim bail for three months . As that temporary relief was nearing expiry, Bisoi approached the Supreme Court.
Proceedings Before the Supreme Court
When the matter came up for hearing, the Bench took note of a crucial fact - by the time the High Court rejected his plea, Bisoi had already spent more than a decade behind bars.
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The judges remarked that it no longer surprises the Court that appeals filed years ago remain unheard. Still, they acknowledged that High Courts face genuine constraints in disposing of matters.
However, the Bench stressed that the right to appeal is a statutory right under Section 374(2) of the Code of Criminal Procedure. “Serious failure of justice could ensue,” the Court noted, if a person remains incarcerated for years and later succeeds in appeal.
Reliance on a 1977 Precedent
The Court referred to its landmark 1977 ruling in Kashmira Singh vs. State of Punjab, where it had questioned the practice of routinely denying bail to life convicts when appeals are not heard for long periods.
Quoting from the earlier judgment, the Bench recalled that no practice “however sanctified by usage” can continue if it causes injustice.
The earlier ruling had warned that keeping a person in jail for five or six years during a pending appeal - especially if he is ultimately acquitted - would be a “travesty of justice.”
The present Bench echoed that concern.
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Court’s Observations
The Supreme Court made it clear that nothing on record suggested that the delay in hearing the appeal was attributable to the appellant .
The judges observed that denying bail solely because a person has been sentenced to life imprisonment cannot be justified when the appeal itself remains pending for years without resolution.
They emphasized that courts must balance the seriousness of the offence with the constitutional promise of fairness.
The Decision
Allowing the appeal, the Supreme Court suspended the life sentence imposed on Muna Bisoi and made the earlier interim protection absolute.
The impugned High Court order was set aside. The Court directed that Bisoi shall continue on interim bail until further orders from the High Court.
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The Bench also 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.
It added that if the appellant does not show interest in pursuing the appeal, the High Court may appoint an amicus curiae (a lawyer appointed to assist the court) and decide the case on 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
