By interpreting Article 21 of the Indian Constitution Justice Iyer's Bench directed the State to provide free legal services to accused person in custody. Indeed, his profound contribution to prison jurisprudence in a few criminal cases had given shape to rehumanisation of the sentencing system in India. The Reformative theory, in contrast to deterrence theory, become deep-rooted in the criminal justice system in the wake of the Land mark rulings of Justice Iyer. While a larger Bench of the Supreme Court of India had upheld the constitutionality of death sentence, Justice Iyer imposed stern conditionalities making death penalty a sentencing rarity. One of his rulings on the subject (Rajendra Prasad Singh's case) was followed by Lords Scarmen in the judicial committee of the Privy Council in West Minister. The jurisprudence of bail was humanised by Justice Iyer and this has been a lasting contribution to the liberation of under trial prisoners. In an International Conference of abolition of death penalty, he was invited to deliver an inaugural address by the "Amnesty International" in 1977. In the matter of sentencing Justice Iyer's innovative experiments have been acclaimed. Following some decisions of the trial judges of U.S. and emphasizing the importance of the correctional process in making the learned judge even directed convicts to undergo meditational courses.