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Challenge to High Court judgment on remission classification based on criminal acts under Section 432 of the Code and Article 14 of the Constitution. Analysis: 1. The State of Haryana challenged the High Court's judgment excluding certain convicts from remission benefits based on criminal acts under a notification issued under Section 432 of the Code. The respondent, serving a sentence for rape, questioned the classification of offences for remission denial, alleging discrimination under Article 14 of the Constitution. The High Court, following precedent, held the State cannot carve out exceptions for remission based on heinous offences, directing remission for the respondent. 2. The High Court's earlier judgment in Suresh Kumar's case and the Andhra Pradesh High Court's decision emphasized that Parliament's amendment in Section 433A restricted the State's power to impose remission restrictions. The State argued for a reasonable classification based on criminal acts for remission, while the respondent contended that the State exceeded its authority in creating a classification for remission denial beyond Section 433A's scope. 3. The Supreme Court analyzed the classification's constitutionality under Article 14, emphasizing valid classifications must have an intelligible differentia and rational relationship with the law's objective. Previous decisions upheld the validity of classifications based on the gravity of offences for remission purposes, recognizing the State's discretion in granting or denying remission based on the nature of the offence committed. 4. The Court concluded that the exclusion of convicts from remission benefits under the impugned notification was justified. Offences like rape, dowry death, abduction, murder of a child, NDPS, TADA, and offences against the State were categorized as grave offences deserving exclusion from remission. The Court upheld the State's classification as valid for determining remission eligibility based on the severity of the crimes committed. 5. Regarding the State's power to restrict remission, the Court clarified that while Section 433A limited remission for specific convicts, Section 432 granted the State broad powers for suspension, remission, and commutation. The State could classify convicts for remission eligibility as long as the classification was valid. The Court corrected the High Court's misinterpretation of the Andhra Pradesh High Court's judgment, affirming the State's authority to restrict remission based on valid classifications. 6. The Court acknowledged the limited validity of the notification in question for the year 1995 and upheld the remission benefit granted to the respondent by the High Court. While appreciating the amicus curiae's services, the Court upheld the State's classification in the notification, allowing the appeal to the extent indicated and disposing of the case accordingly.
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