R. Singh v. PPB, 1470 C.D. 2023

Ravinder Singh was granted parole in 2019, with a maximum sentence date of January 16, 2023.
Singh was twice recommitted as a technical parole violator (TPV) (first in 2019 and again in 2021), each time having his sentence date recalculated but credited for time in good standing on parole.
In March 2022, Singh was arrested on new criminal charges and did not post bail, leading to his detention and subsequent guilty plea for DUI and possession charges.
The Board then recommitted Singh as a convicted parole violator (CPV) in March 2023, denied him credit for time at liberty on parole, and recalculated his maximum sentence date to August 24, 2025.
Singh filed for administrative relief, arguing improper denial and revocation of credit, which was denied; he then appealed to the Commonwealth Court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Credit for time confined solely on Board’s warrant	Singh argues he is owed credit for the 274 days he was confined as a TPV before reparole in 2021	Board argues this period was served as backtime and already counted toward his sentence	Court agreed with Board; no credit is due for time served as backtime
Revocation of previously granted credit for time on parole in good standing	Singh argues the Board cannot revoke previously granted street time credit when recommitted as a CPV for offenses that occurred after those periods	Board argues amended statute gives it authority to revoke such credit upon later CPV recommitment	Court agreed with Board; statute now expressly allows forfeiture

Gaito v. Pa. Bd. of Prob. & Parole, 412 A.2d 568 (Pa. 1980) (addresses parolee credit for pre-sentence incarceration and bail issues)
Martin v. Pa. Bd. of Prob. and Parole, 840 A.2d 299 (Pa. 2003) (clarifies credit allocation for parolees detained on multiple causes)
Pittman v. Pennsylvania Board of Probation & Parole, 159 A.3d 466 (Pa. 2017) (Board must articulate reasons for denying CPV credit for time at liberty)