Justice Gavai Highlighted, “Shraddhanand’s Case as Precedent for "Middle-Path Law" on Life Imprisonment Without Remission”

Swami Shraddhanand, also known as Murali Manohar Mishra, an 85-year-old self-styled godman convicted for the 1991 murder of his wife Shakereh Khaleeli, had approached the Supreme Court to expedite the decision on his mercy petition. Shraddhanand had been in prison for over 30 years without parole.

On 24th January, 2025 the matter was heard by the Division Bench of Justice BR Gavai and Justice AG Masih, who granted two weeks for the Union government to provide instructions. Advocate Varun Thakur, representing Shraddhanand, emphasized his client’s deteriorating health and urged for a swift decision.

Justice Gavai noted that it was Shraddhanand’s case that set a precedent for life imprisonment without remission, a "middle-path law" between traditional life sentences and the death penalty. The court also remarked on the extensive litigation history, including previous petitions for parole and against the Amazon Prime docuseries Dancing on the Grave, which covers Khaleeli’s murder.

Interestingly, the convicted felon had also moved for Presidential pardon before the President of India, under Article 72 of the Constitution, a fact that was brought before the Court in one of the hearings.

Khaleeli, the granddaughter of Sir Mirza Ismail, Dewan of Mysore, married Shraddhanand in 1986 after ending her first marriage. She disappeared in 1991, and after years of investigation, her body was discovered buried in her Bangalore home. It was revealed that Shraddhanand drugged and buried her alive after securing a power of attorney and will in his favor.

Convicted to death in the year 2000 by a Karnataka court the sentence was upheld by the High Court of State following which he appealed to the Supreme Court that delivered a split verdict in 2007. The matter was then referred to a larger bench which commuted his death sentence to a sentence of imprisonment until death in 2008.