The Supreme Court has held that imprisonment for the remainder of a convict's natural life is a constitutionally valid sentence and cannot be challenged merely because the Indian Penal Code prescribes "imprisonment for life" as one of the punishments. The Court also reiterated that judicial review of the President's or Governor's exercise of clemency powers is confined to limited grounds and cannot be used to seek a reduction of a sentence lawfully modified under Articles 72 or 161 of the Constitution.