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2025 Supreme(SC) 1062

SUPREME COURT OF INDIA
J.B. PARDIWALA, R. MAHADEVAN, JJ.
L. Muruganantham – Appellant
Versus
State Of Tamil Nadu & Others – Respondent
Civil Appeal No. 9487 of 2025 [Arising out of SLP (C) No. 1785 OF 2023]
Decided on : 15-07-2025

Important Points

The judgment establishes that the systemic neglect of prisoners with disabilities constitutes human rights violations, emphasizing the need for comprehensive reforms in prison infrastructure and treatment standards under the RPwD Act, 2016.

Subject

Civil Law - Human Rights

Act Referred

CONSTITUTION OF INDIA: Art.14, Art.21
INDIAN PENAL CODE: S.294(b), S.302, S.304, S.323, S.506(ii)
Nelson Mandela Rules: R.54
PROTECTION OF HUMAN RIGHTS ACT: S.2
RIGHTS OF PERSONS WITH DISABILITIES ACT: S.2, S.3, S.39, S.40, S.45, S.47, S.80
RIGHTS OF PERSONS WITH DISABILITIES RULES: R.15
TAMIL NADU PRISON MANUAL: R.405
TAMIL NADU PRISON RULES: R.196, R.197, R.198(iii), R.845

Headnote

(A) INDIAN PENAL CODE, 1860 - Sections 294(b), 323, and 506(ii) - Rights of Persons with Disabilities Act, 2016 - Human rights violations during incarceration of a physically disabled appellant, leading to inadequate medical treatment and failure to provide necessary accommodations - High Court enhanced compensation from Rs. 1,00,000/- to Rs. 5,00,000/- and recommended disciplinary actions against police authorities - Directions issued to implement provisions of RPwD Act and enhance prison conditions for disabled individuals. (Paras 37-39, 51)

(B) Human Rights Violations - Conditions in prisons, particularly treatment of disabled individuals - Acknowledgment that the prison system requires urgent reforms, ensuring compliance with statutory obligations and international standards. (Paras 27-36)

Facts of the case:
Appellant, a physically challenged individual suffering from Becker Muscular Dystrophy and autism, was wrongfully arrested and detained, during which he faced neglect regarding his health and nutritional needs, subsequently leading to serious deterioration of conditions.

Findings of Court:
The courts found violations of human rights due to systemic neglect by the authorities and established the need for reform to enhance the treatment for disabled prisoners.

Issues: Whether the court should enhance the compensation awarded for human rights violations and whether adequate facilities exist for disabled prisoners in Tamil Nadu.

Ratio Decidendi: The court upheld that existing prison conditions are inadequate and emphasized the necessity of reasonable accommodations and dignified treatment for prisoners with disabilities.

Result: Appeals disposed of with directives for immediate reforms.
Judgement Key Points

Based on the provided legal document, here are the key points regarding the case of L. Muruganantham vs. State Of Tamil Nadu & Others:

Case Details and Parties * The judgment was delivered by a bench comprising J.B. Pardiwala and R. Mahadevan, JJ. of the Supreme Court of India. * The case is Civil Appeal No. 9487 of 2025, arising out of SLP (C) No. 1785 OF 2023 (!) . * The appellant, L. Muruganantham, is a physically challenged individual suffering from Becker Muscular Dystrophy and autism (!) . * The respondent includes the State of Tamil Nadu and various police/prison officials (!) .

Facts of the Case * The appellant was wrongfully arrested on 29.02.2020 based on a false complaint lodged by a henchman of his paternal uncle (!) . * He was detained at the Central Prison, Coimbatore, from 29.02.2020 to 10.03.2020 (!) . * During incarceration, the appellant alleged that he faced neglect regarding his health and nutritional needs due to his disability (!) . * Specific grievances included a lack of ramps, accessible toilets, protein-rich food, and adequate medical treatment (physiotherapy/psychotherapy) (!) (!) . * The appellant claimed that the hostile environment aggravated his mental health conditions, leading to sleep deprivation, chronic pain, and ulceration (!) .

Procedural History and Lower Court Orders * The appellant first filed a complaint before the State Human Rights Commission (SHRC), seeking compensation of Rs. 50,00,000/- (!) . * The SHRC awarded a compensation of Rs. 1,00,000/- and recommended disciplinary action against the arresting officer but dismissed the complaint against the prison authorities (!) (!) . * The appellant approached the High Court of Judicature at Madras (W.P. No. 22431 of 2021) seeking enhanced compensation and directions for prison reform (!) . * The High Court enhanced the compensation to Rs. 5,00,000/- (with Rs. 4,00,000/- borne by the State) and directed disciplinary action against the police officer (!) (!) . * The High Court dismissed the complaint against the prison authorities, stating that the appellant was housed in the prison hospital and received some amenities, though records were inconsistent (!) (!) . * The appellant preferred the present appeal to the Supreme Court (!) .

Issues Considered by the Supreme Court * Whether the order of the High Court enhancing compensation to Rs. 5,00,000/- calls for interference by the Supreme Court (!) . * Whether adequate and appropriate facilities are being made available to prisoners with disabilities in Tamil Nadu prisons in compliance with the RPwD Act, 2016 and UNCRPD (!) .

Court's Findings and Observations * The Court upheld the High Court's finding that the arrest and initial treatment by the police constituted human rights violations (!) . * Regarding compensation, the Court found the amount of Rs. 5,00,000/- awarded by the High Court to be fair, just, and reasonable, and declined to interfere further (!) (!) . * The Court dismissed the claim of human rights violation attributable to the prison authorities in this specific instance, noting they could not be held liable without evidence of wilful negligence, though it acknowledged systemic issues (!) . * The Court expressed deep concern over the systemic neglect of prisoners with disabilities and the lack of specific legal frameworks for them in prisons (!) . * It highlighted that most prison facilities are structurally inaccessible and that prison staff often lack training regarding disability rights (!) (!) . * The Court noted a significant data gap, as the NCRB does not maintain disaggregated data on the disability status of prisoners (!) .

Directives Issued * The Court issued comprehensive directives for the State Government of Tamil Nadu to implement the Rights of Persons with Disabilities Act, 2016 (!) . * Identification and Accessibility: Prison authorities must identify prisoners with disabilities at admission and provide all rules and information in accessible formats (Braille, sign language, etc.) (!) (!) . * Infrastructure: All prison premises must be equipped with wheelchair-friendly spaces, accessible toilets, ramps, and sensory-safe environments (!) . * Audit: A State-level access audit of all prisons in Tamil Nadu must be completed within six months by an expert committee (!) . * Healthcare: Prisons must provide healthcare equivalent to the community, including physiotherapy, speech therapy, psychiatric services, and assistive devices (!) . * Diet: Every prisoner with a disability must be provided a nutritious and medically appropriate diet tailored to their needs (!) . * Training: All prison staff must undergo comprehensive training on the rights of persons with disabilities, including non-discrimination and proper handling of challenges (!) . * Manual Revision: The State Prison Manual must be reviewed and amended within six months to conform with the RPwD Act, 2016 and UNCRPD (!) . * Monitoring: The State must constitute a monitoring committee to conduct periodic inspections and submit compliance reports every three months (!) . * Data Maintenance: The State must maintain and update disaggregated data on the disability status of prisoners and make it available in the public domain (!) . * Visitorial System: The Court directed the constitution of Boards of Visitors and the prompt appointment of non-official visitors to monitor prison conditions (!) (!) . * Reporting: The Director General of Prisons must file a comprehensive compliance report before the State Human Rights Commission within three months (!) .


Legal Category Hierarchy

  • constitutional law
    • fundamental rights
      • right to life and dignity (Para 27, 30, 34)
      • right to equality (Para 27)
  • human rights law
    • disability rights
      • reasonable accommodation (Para 27, 28, 34, 35)
      • statutory compliance (Para 27, 35)
  • administrative law
    • prison administration
      • prison reforms (Para 23, 24, 29, 33)
      • oversight mechanisms (Para 18, 19, 20, 29)
  • crime and sentencing
    • custodial rights
      • illegal arrest (Para 16, 18, 20)
      • custodial torture (Para 4, 11)

Advocates appeared:
For the Petitioner(s):Petitioner-in-person
For the Respondent(s): Mr. Amit Anand Tiwari, Sr. A.A.G. Mr. Sabarish Subramanian, AOR Ms. Devyani Gupta, Adv. Mr. Vishnu Unnikrishnan, Adv. Ms. Saushriya Havelia, Adv. Ms. Tanvi Anand, Adv. Mr. Danish Saifi, Adv. Ms. M Karthiga, AOR

Table of Contents

1. Illegal arrest and incarceration of a person with disabilities — Alleged denial of reasonable accommodation and medical care under the RPwD Act, 2016 — Claim for compensation. (Para 3 , 4 , 5 , 6 )

2. Appellant alleges custodial torture and statutory violations regarding disability rights — Respondents contend adequate medical care and special amenities were provided during incarceration. (Para 11 , 12 , 13 )

3. Arrest violated statutory guidelines — Institutional limitations in prisons do not necessarily constitute deliberate human rights violations — Systemic failure to provide disability-sensitive infrastructure violates fundamental rights. (Para 16 , 18 , 20 , 21 , 22 , 23 , 24 , 25 , 26 , 27 , 28 , 30 , 31 , 32 , 33 )

4. Right to dignity under Article 21 and the RPwD Act, 2016 mandates reasonable accommodation and community-equivalent healthcare for prisoners with disabilities. (Para 27 , 28 , 30 , 34 )

5. Compensation upheld — Comprehensive directives issued for prison accessibility audits, staff sensitization, amendment of Prison Rules, and implementation of the Model Prison Manual, 2016. (Para 22 , 29 , 35 )

6. Are prisoners with disabilities entitled to reasonable accommodations and specialized healthcare during incarceration?

Yes. The right to life under Article 21 and the RPwD Act, 2016 mandates that prisoners with disabilities receive healthcare equivalent to that available in the general community, including physiotherapy and assistive devices, ensuring they live with dignity. (Para 27 , 28 , 30 , 34 , 35 )

7. What standards should govern the administration and oversight of prisons in India regarding inmate rights?

Prisons should align with the Model Prison Manual, 2016, and the United Nations Standard Minimum Rules for the Treatment of Prisoners (Nelson Mandela Rules), incorporating effective visitation systems and independent oversight. (Para 18 , 19 , 20 , 29 )

8. What is the legal significance of maintaining disaggregated data on prisoners with disabilities?

Maintaining such data is required under Article 31 of the UNCRPD and the RPwD Act, 2016, to prevent indirect discrimination and enable targeted policy interventions for accessibility and fair trial rights. (Para 31 , 32 , 35 )

JUDGMENT :

R. MAHADEVAN, J.

Leave granted.

2. Being aggrieved and dissatisfied with the final order dated 29.11.2022 passed by the High Court of Judicature at Madras1[Hereinafter referred to as “the High Court”] in Writ Petition No. 22431 of 2021, the appellant has preferred the present appeal. For the sake of clarity and specificity, the operative portion of the impugned order is reproduced below:

“37. The very casual manner in which the officer replied to our query, as to whether, he had read the judgment in Amesh Kumar v. State of Bihar and another shocks us. Such replies will reflect upon the entire Police force. We are constrained to point out that the compensation awarded by the State Human Rights Tribunal at Rs.1,00,000/- is wholly insufficient and we enhance to Rs.5,00,000/-. We further direct that the enhanced compensation of Rs.4,00,000/- shall be borne by the State as we find that there has been several acts of commissions and omissions by the Police Department for which the 2nd respondent alone cannot be held liable. The other directions of the State Human Rights Commission relating to recovery of the penalty of Rs.1,00,000/- from the 2nd respondent and the direction to take disciplinary action against the second respondent in WP No.22431 of 2021 would stand.

38. In fine WP No.22431 of 2021 will stand partly allowed to the extent indicated above and WP. No.22527 of 2021 will stand dismissed. We also award cost of Rs.25,000/- to the petitioner payable by the State.

39. Before parting with this ease, considering the material that has been placed before us, we feel it is necessary to issue directions to the State Government to effectively implement the provisions of the Rights of Persons with Disabilities Act, 2016. There will be a direction to the Additional Chief Secretary to Government of Tamil Nadu, Home Department to ensure that the District wise Sensitization programmes are conducted for Police Officers including Constables regarding the Rights of Persons with Disabilities. Such programmes shall be so designed that they throw enough light on the provisions of the enactment and the intendment of the legislation. Guidelines should also be issued to the Police Officers as to how they should handle such physically disabled persons. Similar guidelines are also to be issued to the Government Doctors who come across such physically disabled persons who run into conflict with law and brought before them for medical examination. We remind the State that a statutory duty has been cast upon it by the provisions of the Rights of Persons with Disabilities Act 2016, to ensure that such persons live with dignity.

…

42 We therefore direct the Director General of Police to take steps to have a periodical inspection of the CCTV Cameras in all Police Stations and ensure their functioning. In order to achieve this, the Director General of Police is required to make a District Level Officer in-charge of ensuring the functioning of CCTV cameras in certain number of Police Stations in the District and such Officers will be responsible for maintenance of the Cameras and if there is a failure on his part, he should be held accountable for such failure. This effort if taken, will go a long way in curing the malady of non-functioning CCTV Cameras. We hope that the above directions would be complied with in their letter and spirit in the interest of the Police Force itself. Consequently, the connected miscellaneous petition is closed.”

3. The appellant, who is an advocate, is a physically challenged person suffering from Becker Muscular Dystrophy, a progressively degenerative locomotive disability. He was assessed to have 70% disability in 2013, which increased to 80% in 2020. According to the appellant, he also suffers from autism and mental illness.

4. It is alleged by the appellant that due to a civil dispute, a false complaint was lodged against him and his aged mother by one Selvakumar, a henchman of the appellant’s paternal uncle, Dhandapani,

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