Prisoners With Disabilities Have Enforceable Rights To Dignity, Rehabilitation & Accommodation: SC

Last Updated:July 16, 2025, 17:30 IST

The Supreme Court held that denial of reasonable accommodations in custody violates Articles 14 and 21 of the Constitution and breaches the RPwD Act, 2016

The Supreme Court expressed deep concern that there is no existing policy framework. (PTI File)

The Supreme Court has delivered a landmark judgment affirming the constitutional and statutory rights of prisoners with disabilities, declaring that the State is duty-bound to ensure their dignity, humane treatment, and equal access to rehabilitation.

A bench of Justices J.B. Pardiwala and R. Mahadevan held that disabled inmates must not be relegated to the margins of the justice system merely because of their incarceration, and that reasonable accommodations in prison are not a matter of charity but a constitutional and legal obligation.

“The punishment lies only in the restriction of liberty, not in the denial of humane treatment or reasonable accommodations," the bench said. “Lawful incarceration does not suspend the right to human dignity."

The judgment came in a plea by advocate L. Muruganatham, who suffers from Becker Muscular Dystrophy, a degenerative condition resulting in 80% locomotor disability. He challenged the Madras High Court’s order enhancing his compensation from ₹1 lakh to ₹5 lakh after he faced systemic neglect during a wrongful period of incarceration.

The Court, while refusing to enhance the compensation further, acknowledged broader issues of systemic inaccessibility and neglect faced by prisoners with disabilities and issued time-bound, binding directions for prison reforms across Tamil Nadu. These, it held, stem not only from India’s constitutional ethos but also from the Rights of Persons with Disabilities (RPwD) Act, 2016, and Article 15 of the UN Convention on the Rights of Persons with Disabilities (UNCRPD), to which India is a signatory.

The bench said that denial of access, medical treatment, interpreters, assistive devices, or accessible formats within custodial settings cannot be brushed aside as mere administrative gaps. They amount to violations of Articles 14 and 21 of the Constitution.

“Such systemic omissions lead to indirect discrimination," the Court said, especially when a prisoner’s ability to participate in their own defence is hindered due to inaccessible procedures. The absence of interpreters, proper communication support, or assistive technology, it said, can result in miscommunication, delays in justice, and denial of fair hearing.

The Court expressed deep concern that there is no existing policy framework, unlike the minimal protections afforded to women prisoners, to protect the rights of disabled inmates or members of the transgender community.

The appellant had submitted that his physical condition had worsened in custody due to the lack of protein-rich food, assistive devices, and proper healthcare. The Court noted that while he did not receive certain specific facilities, records show that he remained in the prison hospital and was given some special amenities. The failure to provide particular food items or advanced interventions, the bench said, stemmed from “institutional limitations" rather than malice.

Importantly, the Court clarified that Article 21 does not extend to personalised or luxurious food preferences, but mandates “adequate, nutritious and medically appropriate food." What matters is whether the State fulfilled its obligation to safeguard the prisoner’s basic health and dignity.

Recognising the structural neglect of disabled inmates, the Court framed 15 actionable directives aimed at transforming custodial spaces into inclusive, rights-compliant environments.

These include:

• Mandatory identification of prisoners with disabilities at the time of admission.
• Accessible prison infrastructure with ramps, modified toilets, wheelchair paths, and sensory-safe spaces.
• Dedicated physiotherapy and psychotherapy spaces in every prison.
• Access audits to be completed within six months by expert committees.
• Compliance with RPwD Act provisions, Harmonised Guidelines (2021), and related prison rules.
• Provision of healthcare services, including regular physiotherapy, psychiatric services, and assistive devices.
• Sensitisation of prison and medical staff to recognise and support disabling conditions without bias.
• A medically appropriate diet for all prisoners with disabilities, tailored to individual needs.
• Lifesaving therapies and urgent interventions, either on-site or linked to government hospitals.
• Mandatory training for prison officials on disability rights and reasonable accommodation duties.
• Review of the State Prison Manual within six months to align with RPwD and UNCRPD standards.
• Regular consultation with disability rights groups to frame inclusive prison policies.
• Monitoring committee to inspect and report on prison conditions every three months.
• Maintenance of disability-disaggregated data to track needs, services, and accommodations.
• Comprehensive compliance report to be filed before the State Human Rights Commission by the Director General of Prisons within three months.

While the Court upheld the Madras High Court’s ₹5 lakh compensation order as “just and reasonable," it made it clear that the broader issue lies in institutional failure.

“A systemic transformation is urgently required, one grounded in compassion, accountability, and a firm constitutional commitment to dignity and equality," the bench declared.

Sanya Talwar

Sanya Talwar, Editor at Lawbeat, has been heading the organisation since its inception. After practising in courts for over four years, she discovered her affinity for legal journalism. She has worked previousl...Read More

Sanya Talwar, Editor at Lawbeat, has been heading the organisation since its inception. After practising in courts for over four years, she discovered her affinity for legal journalism. She has worked previousl...

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