Multiple murders – Conviction upheld Appellant convicted for murders of Dr. A. Malik Mohammed, his watchman Gnanaprakasam, and abduction/murder of Katheeja Bibi; conviction under Sections 449, 302 (three counts), 364, 392, 201 IPC affirmed. (Paras 5–10, 16) High Court – Enhancement of sentence High Court, exercising suo motu revisional jurisdiction, enhanced sentence from life imprisonment to imprisonment for remainder of natural life; held impermissible absent appeal by State/victim/complainant. (Paras 10, 17–19)

  Gopi @ Sahaya Puruna v. State (2026 INSC 880, decided 18 August 2026):

Headnotes

1. Multiple murders – Conviction upheld Appellant convicted for murders of Dr. A. Malik Mohammed, his watchman Gnanaprakasam, and abduction/murder of Katheeja Bibi; conviction under Sections 449, 302 (three counts), 364, 392, 201 IPC affirmed. (Paras 5–10, 16)

2. High Court – Enhancement of sentence High Court, exercising suo motu revisional jurisdiction, enhanced sentence from life imprisonment to imprisonment for remainder of natural life; held impermissible absent appeal by State/victim/complainant. (Paras 10, 17–19)

3. Appellate jurisdiction – Limits In appeal filed by accused, appellate court cannot enhance sentence; enhancement only permissible if State or complainant appeals. Reliance placed on Nagarajan v. State of Tamil Nadu (2025 INSC 802). (Paras 17–19)

4. Consecutive life sentences – Illegality Trial Court and High Court directed multiple life sentences to run consecutively; contrary to settled law in Muthuramalingam v. State (2016) 8 SCC 313; life imprisonment must run concurrently with other life or fixed‑term sentences. (Paras 20–22)

5. Modification of sentence – Concurrent terms Supreme Court modified direction; sentences to run concurrently; enhancement to remainder of natural life set aside. (Paras 23)

6. Revisional jurisdiction – Improper exercise High Court erred in exercising suo motu revisional powers to worsen position of accused in absence of appeal for enhancement. (Paras 17–19, 23)

Analysis of Facts and Law

Factual Background

• Appellant and co‑accused Ambarasu committed a brutal triple murder and abduction in 2007.

• Trial Court convicted appellant, awarding multiple life sentences and fixed‑term sentences, directed to run consecutively.

• Ambarasu later tried separately, initially sentenced to death, reduced by High Court to remainder of natural life.

• High Court enhanced appellant’s sentence similarly, despite no appeal for enhancement.

Legal Issues

1. Whether High Court could enhance sentence in appeal filed by accused without appeal by State/victim.

2. Whether consecutive life sentences are legally sustainable.

Law Applied

• Section 386 CrPC: Appellate court may alter findings/sentence but not enhance in appeal filed by accused.

• Section 397/401 CrPC: Revisional jurisdiction cannot be used to worsen accused’s position absent appeal.

• Muthuramalingam v. State (2016): Life imprisonment means imprisonment for natural life; cannot run consecutively with other life/fixed‑term sentences.

• Nagarajan v. State of Tamil Nadu (2025): Appellate court cannot enhance sentence in appeal filed by accused.

Court’s Reasoning

• High Court’s enhancement of sentence to remainder of natural life was impermissible; left appellant worse off for filing appeal.

• Consecutive life sentences unworkable; must run concurrently.

• Appellate rights of accused are constitutional and statutory; cannot be undermined by enhancement absent proper appeal.

Outcome

• Supreme Court set aside High Court’s enhancement.

• Directed all sentences to run concurrently.

• Appeals disposed accordingly.