In Israfil @ Pappu @ Naimuddin Khan v. State of Madhya Pradesh (decided on 23 June 2026), the Supreme Court reaffirmed that sentencing must remain proportionate and that a long period without similar criminal conduct is a significant mitigating factor. The appellant was convicted under Sections 467, 468, and 471 of the IPC for using a forged revenue document as surety. While upholding the conviction, the Court reduced the sentence to the period already undergone, noting that the appellant had not engaged in any similar offence since the incident in 2014 and had endured over 12 years of criminal proceedings. Relying on Padum Kumar v. State of Uttar Pradesh (2020), the Bench held that punishment should balance the gravity of the offence with the offender’s conduct, possibility of reform, and surrounding circumstances. The judgment reiterates that conviction and sentencing are distinct issues, allowing courts to maintain guilt while modifying punishment in the interests of justice.