In Parveen Kumar @ Parveen Chauhan v. State of Haryana (2026 INSC 667), a life convict sought premature release under the 2002 Haryana Remission Policy (Article 161), but the State applied the stricter 2008 statutory policy. The High Court relied on State of Haryana v. Raj Kumar (2021), which called the 2002 policy a mere "statutory memo." The Supreme Court (Justices Karol and Kotiswar Singh) held Raj Kumar was per incuriam, since it ignored the 3-judge bench ruling in State of Haryana v. Jagdish (2010), which treated the 2002 policy as constitutional in nature. A smaller bench cannot override a larger bench; such conflicting rulings must instead be referred onward. The appeal was allowed, Jagdish restored, and the State directed to reconsider remission within four weeks.