Delhi HC Orders Reconsideration of Convict’s Plea for Early Release in Triple Murder Case
The convict, Naveen Ahuja, approached the court seeking premature release in the murder case of his wife and two minor children;
The Delhi High Court has directed the Sentence Review Board (SRB) to reconsider the plea of a man convicted of murdering his wife and two young children, after quashing the Board’s earlier decision to deny him premature release.
The Board had earlier turned down the plea, citing the “brutal” nature of the crime, which it said had shaken public confidence. It also pointed to the convict’s poor conduct in jail, concluding that these factors made him unfit for premature release.
Challenging this decision, the convict, who is currently serving life imprisonment, approached the High Court. He was convicted under Section 302 of the Indian Penal Code, 1860, and Sections 25 and 27 of the Arms Act, 1959, in FIR registered at P.S. Kapashera. The trial court had initially sentenced him to death, but the High Court later commuted the sentence to life imprisonment.
The bench of Justice Sanjeev Narula noted that the petitioner had already undergone 17 years, 11 months, and 21 days of actual incarceration, and 21 years, 4 months, and 8 days, including remission.
Observing that his conduct had been satisfactory, the court recorded, “The Petitioner has been granted paroles and furloughs on nearly 30 occasions during his incarceration, and his conduct during each of these periods has been reported to be satisfactory. Moreover, the conduct of the Petitioner inside the prison has also been found satisfactory, except for a punishment dated 14th June, 2011".
Referring to the Social Investigation Report dated 26th June, court added that the petitioner appeared fit for a positive recommendation by the SRB. The Probation Officer had opined that the petitioner seemed to have lost his potential for committing crime and could be reclaimed as a useful member of society.
“Significantly, the Board’s order does not meaningfully engage with the reformative progress of the Petitioner, as documented in the Social Investigation Report and the opinion of the Probation Officer, both of which support a positive consideration of his case. These reports suggest that the Petitioner has shown signs of rehabilitation and may be reintegrated into society as a law-abiding citizen,” court added.
Reliance was placed on Santosh Kumar Singh v. State, where the High Court had recently examined the approach adopted by the SRB in considering premature release cases. It had been observed that the Board’s approach lacked legal compliance, proper reasoning, and adherence to the reformative framework envisaged under Rule 1244 of the Delhi Prison Rules, 2018.
Court had then emphasised that while the gravity of the offence may be relevant, it cannot be the sole or overriding ground for rejection. Instead, the SRB must assess reformation, conduct, and the likelihood of reintegration.
Taking note of this, the single judge bench remanded the matter back to the SRB for reconsideration in accordance with law, keeping in view the principles and observations made, without being influenced by its earlier decision.
With these directions, the petition was disposed of.
Appearance for Petitioners: Advocates Warisha Farasat and Suvarna
For Respondents: Advocates Amol Sinha, ASC (Crl.) with Kshitiz Garg, Ashvini Kumar, Chavi Lazarus, Nitish Dhawan and Sanskriti Nimbekar
Case Title: NAVIN AHUJA VS OFFICE OF LT. GOVERNOR OF DELHI, NCT OF DELHI & ANR.
Judgement Date: 22 August 2025
Bench: Justice Sanjeev Narula