By 
The Supreme Court on August 19 gave the Odisha Sentence Review Board one final opportunity to take a decision on the premature release of Dara Singh, alias Rabindra Kumar Pal, who is serving a life sentence in connection with the 1999 murder of Australian missionary Graham Staines and his two minor sons.
The Court orally indicated that if the Board does not take a decision by the next hearing, it may decide Singh’s plea itself.
A Division Bench of Justice Manoj Misra and Justice Vijay Bishnoi was hearing the matter. The Court was informed that no decision had been taken yet. At the previous hearing, the Court had directed the Odisha Government to take a decision on Singh’s premature release by August 19.
Court Questions Delay
The advocate appearing for the State initially sought a passover. When the Court questioned why there was a delay, he placed on record a letter issued by the Directorate General of Prisons.
The Court questioned why the letter was being placed on record when what mattered was a decision by the Sentence Review Board.
The advocate told the Court that the DG Police had sought information about Singh’s antecedents from Uttar Pradesh, where he belongs.
“We Can’t Tolerate This”
Justice Misra orally said that the Court would not tolerate indecisiveness. He directed the Sentence Review Board to take a decision on Singh’s plea by September 2. If it failed to do so, the Court itself would decide the matter.
“You take a decision whatever you want or else we will take a decision…We are not concerned how you are communicating; just take a decision. We can’t tolerate this avoiding taking a decision,” he said.
The Court ordered:
“This matter has been adjourned time and again to enable the respondents to take a decision on the plea of remission of sentence awarded to the petitioner who is incarcerated for a period exceeding 26 years. It appears that when the matter was adjourned last, the State Sentence Review Board was in the process of taking a decision on the petitioner’s plea. Based on that, the matter was adjourned. Today, the learned counsel for the respondent has placed before us a letter of the Directorate of Prison and Correctional Services addressed to the counsel, wherein he stated that the report from the district jail, Kendujhar, Orissa is yet to be received. We are not informed of the decision of the sentence review board. List this matter on 2 September. The sentence review board should take a decision and apprise us.”
Plea For Release
Singh has approached the Supreme Court seeking remission of his sentence. He says that he has spent more than 25 years in prison.
Under the State’s remission policy, convicts whose death sentences have been commuted to life imprisonment may be considered for remission after completing 25 years in prison.
Advocate Vishnu Shankar Jain, along with Advocate Hari Shankar Jain, represents Singh. They have argued that Singh meets the eligibility requirements for remission.
Singh has expressed regret for the offences committed more than two decades ago and has sought an opportunity to “give back to society” through service-oriented work.
He has also said that he had no personal animosity towards the victims and explained his actions as a result of a “fit of youthful rage”.
Relying on the reformative theory of punishment, Singh has sought premature release on the ground that he should be given an opportunity to return to society as a reformed person.
His plea also relies on the Supreme Court’s 2022 judgment allowing the premature release of convicts in the Rajiv Gandhi assassination case.
The Odisha State Sentence Review Board has reportedly recommended his release on the ground of “good behaviour”.
On July 14, 2026, the Bench of Justice Manoj Misra and Justice Vijay Bishnoi had directed the Odisha Government to take a decision on Singh’s premature release by August 19.
Three Murder Convictions
Rabindra Kumar Pal, better known as Dara Singh, is serving three separate life sentences for three killings involving victims from religious minority communities.
The most prominent case is the murder of Australian Christian missionary Graham Staines and his two minor sons, Philip Staines, aged 10, and Timothy Staines, aged 6.
On January 22, 1999, at Manoharpur village in Keonjhar district, Odisha, a mob led by Dara Singh set fire to the station wagon in which Staines and his sons were sleeping. The three victims could not escape and were burnt to death.
Singh was also convicted for the murder of Shaikh Rahaman, a Muslim garment trader, who was beaten and burnt to death.
In another case from the same period, he was convicted for killing Arul Das, a Catholic priest, who was attacked with an arrow while trying to escape from a church that had been set on fire.
Before these convictions, Singh had also been implicated in the killing of Shaikh Imam, a Muslim cattle truck driver’s assistant. Imam was beaten to death in September 1998 after his vehicle was looted and set on fire.
Singh was acquitted in that case in 2006 for lack of sufficient evidence.
Graham Staines Case
The murder of Graham Stuart Staines and his two minor sons is the case in which Singh was initially sentenced to death.
Staines was an Australian Christian missionary who had worked among tribal communities in Odisha, particularly with leprosy patients, for several years.
In January 1999, Staines was sleeping inside his station wagon with his two sons when a mob arrived at Manoharpur village. The mob surrounded the vehicle and set it on fire while preventing the occupants from escaping.
Following a CBI investigation, 14 adults, including Singh, were put on trial. One minor was tried separately before the Juvenile Court.
In September 2003, the Sessions Court convicted the accused. The other accused were sentenced to life imprisonment, while Dara Singh was sentenced to death.
In 2005, the Orissa High Court commuted Singh’s death sentence to life imprisonment. The Supreme Court upheld that decision in 2011.
In its January 21, 2011 judgment, the Supreme Court observed:
“In the case on hand, though Graham Staines and his two minor sons were burnt to death while they were sleeping inside a station wagon at Manoharpur, the intention was to teach a lesson to Graham Staines about his religious activities, namely, converting poor tribals to Christianity. All these aspects have been correctly appreciated by the High Court and modified the sentence of death into life imprisonment with which we concur.”
The death sentence was therefore commuted to life imprisonment because the case was held not to meet the “rarest of rare” standard required for capital punishment.
The crime took place on January 22, 1999, when the mob allegedly led by Singh attacked the vehicle in which Staines and his two sons were sleeping. All three were killed.
Singh has now spent more than 26 years in prison and is seeking remission under the applicable State policy.
The Supreme Court has adjourned the matter to September 2. By then, the Sentence Review Board has been directed to take a decision and inform the Court.
Case Details: Rabindra Kumar Pal @ Dara Singh vs State of Odisha (Diary No. 11407/2024)
