Punjab & Haryana High Court, Chandigarh
Citation2006 AIR (SC) 3385, (2006) 8 SCC 161
CourtSupreme Court of India
Date11 October 2006
Year2006
BenchArijit Pasayat, S.H. Kapadia JJ.
Acts/ArticlesArticle 72, Article 161, Article 32
CategoryConstitutional Law, Criminal Law

Key Principle Established

Presidential/Governor's pardon power is not immune from judicial review. Pardon can be cancelled if obtained by fraud, misrepresentation, or non-application of mind.

Brief Facts

The petitioner’s father was murdered. The convicted murderer (Respondent No. 2) was granted remission of about 7 years of unexpired imprisonment by the Governor. The petitioner challenged the pardon.

Ratio Decidendi

The Supreme Court held that the pardon/remission power under Articles 72 and 161 is subject to judicial review. The Court can examine whether the power was exercised on relevant material, without extraneous considerations, and not vitiated by mala fides.

Impact & Significance

This judgment established that no power is above judicial scrutiny — even the mercy/pardon power of the President and Governor can be reviewed by courts if exercised arbitrarily or on extraneous considerations.

Tags & Related Topics

Constitutional Law Criminal Law Article 72 Article 161 Article 32
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Disclaimer

This judgment summary is for educational and research purposes. While care has been taken to accurately represent the ratio and findings, for authoritative reference always consult the original judgment text from official sources (SCC Online, AIR, Manupatra, or court websites).

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