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Karan Mandal v. State (Nct of Delhi)

Delhi HC8 Jan 2026W.P.(CRL)/55/2026

Case brief

AI extract

What is this about?

Delhi High Court, Manoj Jain, J., 08.01.2026, W.P.(CRL) 55/2026, Karan Mandal v. State (NCT of Delhi). Keywords: furlough; parole; jumped furlough; re-arrest; Rule 1223 Delhi Prison Rules 2018; Rule 1224(iii) Delhi Prison Rules 2018; good conduct reports; habitual offender; reconsideration by Competent Authority; Satender Alias Gajender W.P(C) No.(CRL) 221/2022 order dated 09.05.2022; rejection order dated 06.10.2025 set aside; four weeks; Jail Superintendent compliance.

What did the court decide?

Rejection order dated 06.10.2025 set aside; Competent Authority directed to reconsider the furlough request under Rule 1223 of the Delhi Prison Rules, 2018 and per the directions in Satender Alias Gajender (supra), uninfluenced by the earlier furlough jump, preferably within four weeks; copy of order to be sent to Jail Superintendent for compliance.

Karan Mandal Vs State (Nct of Delhi) — Delhi HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

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Issue for consideration

Whether the petitioner, who had earlier jumped furlough (released 31.10.2015 to 15.11.2015) and was re-arrested only on 28.07.2022, is nevertheless entitled to have his furlough request reconsidered under Rule 1223 of the Delhi Prison Rules, 2018, notwithstanding the disqualification stipulated in Rule 1224(iii).

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Court's answer

The rejection order of 06.10.2025 is set aside; the Competent Authority is directed to reconsider the petitioner's request for furlongh in view of Rule 1223 of the Delhi Prison Rules, 2018 and in light of the specific directions in Satender Alias Gajender (supra), without being influenced by the fact that the petitioner had earlier jumped furlough, expeditiously and preferably within four weeks.

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Detailed headnote1 paragraphs

Karan Mandal v. State (NCT of Delhi), W.P.(CRL) 55/2026 (Delhi HC, decided 08.01.2026, Manoj Jain, J., oral): Petitioner's furlough request had been rejected on 06.10.2025 under Rule 1224(iii) of the Delhi Prison Rules, 2018 because he had earlier been released on furlough (31.10.2015 to 15.11.2015), jumped furlough and was re-arrested only on 28.07.2022. Counsel contended that since re-arrest the petitioner had not availed furlough or parole, had maintained good conduct and earned rewards in three annual good conduct reports, was not a habitual offender, and was eligible under Rule 1223, relying on Satender Alias Gajender vs. State (Govt. of NCT of Delhi), W.P(C) No.(CRL) 221/2022 (order dated 09.05.2022). The Court set aside the rejection order and directed the Competent Authority to reconsider the furlough request under Rule 1223 and in light of the directions in Satender Alias Gajender (supra), without being influenced by the earlier furlough jump, preferably within four weeks; petition disposed of, with a copy to the Jail Superintendent for information and necessary compliance.

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$~43

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IN THE HIGH COURT OF DELHI AT NEW DELHI

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% Date of Decision: 08^th January, 2026

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- W.P.(CRL) 55/2026 KARAN MANDAL .....Petitioner

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Through: Mr. Sidharth Yadav with Mr. Anmol Panday, Mr. Vikas Deep, Ms. Jyoti Yadav, Advocates.

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versus

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STATE (NCT OF DELHI) .....Respondent Through: Mr. Sanjay Lao, SC for State.

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CORAM:

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HON'BLE MR. JUSTICE MANOJ JAIN J U D G M E N T (oral)

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Petitioner is aggrieved by order dated 06.10.2025 whereby his request of furlough has been declined.

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The reason of rejection is very categoric.

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Since on one earlier occasion, the convict had been released on furlough with effect from 31.10.2015 to 15.11.2015 and since he jumped furlough and did not surrender on due date and was re-arrested on 28.07.2022 only, the benevolent provision of furlough has been denied to him in terms of Rule 1224(iii) of Delhi Prison Rules, 2018 which stipulates that any such person who has been re-arrested, while released on parole or furlough, would not be entitled for furlough.

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Learned counsel for petitioner, however, submits that after his re-arrest on 28.07.2022, the petitioner has never availed furlough or parole.

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He also submits that in terms of Rule 1223 Delhi Prison Rules, 2018, he has become eligible, again, since he has maintained good conduct in the prison and has earned rewards in last three annual good conduct reports and

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Signature Not Verified

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W.P.(CRL) 55/2026

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Digitally Signed By:SONIA THAPLIYAL Signing Da te:0 9.01.2026 18:36:38

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continues to maintain good conduct. He also submits that petitioner is not a habitual offender and, therefore, despite the fact that he had earlier jumped the furlough, his case deserves to be considered in terms of Rule 1223 of Delhi Prison Rules, 2018.

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In this regard, he strongly relies upon order dated 09.05.2022 passed in Satender Alias Gajender vs. State (Govt. Of NCT of Delhi) : W.P(C) No.(CRL) 221/2022.

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In view of the above, while setting aside the rejection order, the Competent Authority is directed to reconsider the request for grant of furlough in view of the Rule 1223 of Delhi Prison Rule, 2018 and also in light of the specific directions contained in Satender Alias Gajender ( supra), without being influenced by the fact that the petitioner had, on earlier occasion, jumped furlough.

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