Rabindra Kumar Pal, better known as Dara Singh, the principal convict in the 1999 burning-alive of Australian missionary Graham Staines and his two young sons, Philip (10) and Timothy (6), at Manoharpur village in Odisha’s Keonjhar (now Kendujhar) district is likely set to walk free after more than 25 years in prison. If released, no one convicted in the case will remain in prison.
The Odisha State Sentence Review Board has recommended his release from jail on ground of “good behaviour.” On July 14, 2026, a bench comprising of Justices Manoj Misra and Vijay Bishnoi of the Supreme Court through its order had asked the Odisha Government to take a decision on the premature release of Singh by August 19. Reportedly, the bench also made an oral observation that, “You take a decision by August 15. Let him also celebrate Independence Day by then.” Reported the Hindustan Times.
Singh, who is said to be associated with the Bharatiya Janata Party and the Bajrang Dal, is serving life imprisonment not only for the murder of Australian missionary Graham Staines and his two sons, but also for the 1999 murder of Catholic priest Arul Das, who was shot with an arrow while fleeing a building that had been set on fire. Reported the new Indian Express. He was also convicted for the murder of Shaikh Rahman, a Muslim garment merchant, who was brutally assaulted, had his hands severed, and whose body and garment stall were set ablaze.
In July 2024, the Supreme Court had sought the Odisha government’s response on a plea filed through advocate Vishnu Shankar Jain seeking Singh’s remission of sentence and release, asserting that he met the state government’s criteria for granting remission (i.e. 25 years). The reformative theory of Justice V. R. Krishna Iyer was invoked and reliance was placed on the Court’s 2022 judgment permitting the premature release of the convict in the Rajiv Gandhi assassination case.
The current remission, therefore reflects a broader pattern in India of state governments ruled by the incumbent-BJP granting remission to those convicted in cases of gross communal violence. One such earlier instance was the release of the convicts in the 2002 Bilkis Bano gang rape and family murder case, a decision that remained in force until it was struck down by the Supreme Court.
It is worth noting that prior to this; Singh’s plea for remission has been evaluated on five separate occasions, and has been turned down each time, with the most recent rejection occurring in February 2024.
How the Remission Was Filed and Processed
Singh’s possible release has drawn political attention in the past. During a campaign for his release in 2022, when the BJD government was in power, Sudarshan TV editor-in-chief Suresh Chavhanke attempted to meet him in prison but was denied permission. Mohan Charan Majhi, (now the Chief Minister of Odisha), had also joined a protest outside the jail demanding Singh’s release. However, the Board’s consideration of Singh’s case was based on the prescribed remission process and the reports submitted by the relevant authorities. This clearly establishes that organised political demand for Singh’s release predates, by a considerable margin, the administrative process that has now produced it.
At its September 2025 meeting, the Board considered 107 cases. It recommended the release of 18 life convicts, rejected 75 applications, and deferred 14, including Singh’s. Singh’s case remained pending because the Board required a fresh report from his home district.
According to The Hindu, the State Sentence Review Board met in the first week of July 2026 to consider the premature release of eligible life convicts. Among the cases reviewed was that of Dara Singh. In his petition before the Supreme Court, he stated that he deeply regretted the offences committed over two decades earlier and sought an opportunity to “give back to society” through service-oriented work. He also claimed that he bore no personal animosity towards the victims and described his actions as the result of “youthful rage.” Singh was 37 years old at the time of his arrest!
Under Odisha’s 2022 premature-release guidelines, a convict whose sentence has been commuted from death to life becomes eligible for remission consideration after 25 years in custody, subject to a recommendation from the State Sentence Review Board (SSRB) and government approval. Five out of six members of the SSRB belong to the executive branch of government. The presence of ruling-party legislators, when the CM has supported Singh’s release, on the deciding panel raises questions whether the government will independently apply its mind.
Comparison with the Bilkis Bano Case
Setting the two cases side by side is useful because they involve a similar factual pattern. In both instances, persons convicted of life imprisonment in communal hate-crime cases were considered for or granted premature release.
The release in Bano’s case followed a plea filed by one convict, Radheshyam Bhagwandas Shah, who argued he had already served over 15 years and sought early release. Shah had first tried this route in Gujarat, where the Gujarat High Court itself had indicated that Maharashtra, the state where his trial was actually conducted after the Supreme Court moved it there on Bano’s plea, was the appropriate government to decide his remission, not Gujarat. On May 13, 2022, Supreme Court order directed Gujarat (rather than Maharashtra) to decide the remission question. Acting on the Court’s direction, the Gujarat government formed a committee, which went on to recommend that the sentences of all 11 convicts in the case be remitted. The panel that granted remission included BJP legislators, the same party that governed Gujarat at the time of the riots. One of those legislators publicly defended the convicts by remarking that some of them were “Brahmins” with good values. Reported NDTV.
Several activists, along with Bilkis Bano herself petitioned the Court in November 2022. On January 8, 2024, Justices B.V. Nagarathna and Ujjal Bhuyan quashed the remission, holding that Gujarat was never the appropriate government and that the May 2022 order directing Gujarat to decide had itself been obtained by concealing material facts. The convicts were ordered back to prison within two weeks.
In Bano’s case, when the Gujarat government had released eleven convicts on August 15, 2022, they were welcomed with sweets and had their feet touched by supporters. Singh has for years been celebrated by sections of the Hindu right. Organisations such as the Dharmarakhyak Sri Dara Singh Bachao Samiti and Dara Sena have publicly campaigned for his release and portrayed him as a defender of Hinduism.
Given this, especially when the incumbent Odisha Chief Minister has also, before assuming office, expressed support for Singh’s release, there is a significant possibility that Singh’s release too will receive a public welcome similar to that accorded to the Bano’s convicts. The repeated public glorification of individuals convicted in cases of communal violence by organisations affiliated with or aligned to the BJP-RSS ecosystem raises serious concerns about the social and political messaging such releases convey.
While concealment of material facts was the decisive ground in Bano’s case, the Court also separately described Gujarat’s orders as stereotyped and passed without application of mind. Odisha’s Sentence Review Board considered Singh’s file within a batch of dozens of prisoners in a single sitting arguably meets the same structural vulnerability.
Five factors were decided in Laxman Naskar v. Union of India (2000), to decide on pre-mature release of convicts, namely:
i) Whether the offence is an individual act of crime without affecting the society at large?
ii) Whether there is any chance of future recurrence of committing crime?
iii) Whether the convict has lost his potentiality in committing crime?
iv) Whether there is any fruitful purpose of confining this convict any more?
v) Socio-economic condition of the convict’s family.
The first factor alone arguably requires reckoning with the fact that his is not a single offence but three separate convictions, spanning roughly a year, each targeting a different religious minority.
(The legal research team of CJP consists of lawyers and interns; this judgement primer has been worked on by Tanishka Shah)
Related:
Remembering the Graham Staines Murder
Bilkis Bano gets Justice: Supreme Court strikes down remission