MR. MANI @ VELUMANI V THE STATE AND OTHERS, 2024 (MAD) 369
Facts: The petitioner, Mani @ Velumani, challenged the decision of the State Government rejecting his application for premature release, made in accordance with the policy outlined in G.O.(Ms)No.488, Home (Prison-IV) Department dated 15.11.2021. Mani’s application had been recommended by the State Committee, which found that he had fulfilled the required conditions. However, the Government rejected his request on the grounds that the offense committed by him was "heinous" and that he had not served 14 years in prison, thereby deeming his remission to be premature.
Issue:Whether the State Government can reject an application for premature release of a convict solely by invoking the term "heinous crime" without providing adequate reasoning for such a rejection.
Observation: The Court held that merely citing the offense as "heinous" was an insufficient ground for rejecting the application for premature release. The Court emphasized that when exercising discretionary powers, the Government is required to provide specific, cogent reasons for its decision. It was observed that the reasons for such decisions are the cornerstone of administrative action and must be clearly articulated. The Court further noted that under the applicable policy, a convict is eligible for premature release after serving 10 years of imprisonment, provided the conditions are met. Therefore, the Court examined whether the Government had exercised its discretion in compliance with the rules of natural justice, ensuring that the decision was based on a thorough and reasoned evaluation of the petitioner’s case.
