in january 2014, a three-judge panel headed by chief justice of india palanisamy sathasivam commuted sentences of 15 death-row convicts, ruling that the "inordinate and inexplicable delay is a ground for commuting death penalty to life sentence". supreme court of india ruled that delays ranging from seven to 11 years in the disposal of mercy pleas are grounds for clemency. the same panel also passed a set of guidelines for the execution of a death row convict, which includes a 14-day gap from the receipt of communication of the rejection of first mercy petition to the scheduled execution date, after going through the shatrughan chouhan vs union of india case.