Court establishes the necessity for coordinated mechanisms across jurisdictions to safeguard the rights and dignities of prisoners with disabilities under the RPwD Act, mandating compliance and accountability.

ORDER :

Mehta, J.

1. The present proceedings bring to the fore issues of considerable importance concerning the rights, conditions of detention, and institutional safeguards available to prisoners with disabilities within prison systems across the country. The matter necessitates a closer examination of the extent to which the mandate of the Rights of Persons with Disabilities Act, 2016 [For short, “RPwD Act, 2016”], and the constitutional guarantees of dignity, equality, and non-discrimination are being effectively realised in custodial settings, and whether adequate mechanisms exist to secure their meaningful implementation.

2. This Court, vide order dated 2nd December, 2025, noted that the grievances raised by the petitioner herein stand substantially ventilated by the directions issued by this Court in L. Muruganantham v. State of Tamil Nadu and Others , (2025) 10 SCC 401. In the said decision, this Court laid down an exhaustive framework to safeguard the rights of prisoners with disabilities, inter alia directing identification of such prisoners at the time of admission, provision of accessible infrastructure including ramps and accessible toilets, availability of healthcare and assistive devices, training and sensitisation of prison staff, conduct of accessibility audits, maintenance of disability-related data, formulation of inclusive prison manuals, establishment of monitoring mechanisms, and submission of periodic compliance reports to ensure effective implementation of the mandate of the RPwD Act, 2016 and constitutional guarantees.

3. However, having regard to the submissions advanced by learned counsel appearing for the petitioner, this Court deemed it appropriate to issue certain further directions, in addition to those contained in L. Muruganantham (supra). In brief, this Court directed that the directions issued in L. Muruganantham (supra) be extended to all States and Union Territories; that a robust, independent and accessible grievance redressal mechanism be established for prisoners with disabilities; that facilities for inclusive education be ensured; that the provisions of Section 89 of the RPwD Act, 2016 be made applicable to prison establishments, along with appropriate awareness and sensitisation measures; that the States and Union Territories indicate structured mechanisms for the provision of assistive devices and support equipment; and that enhanced visitation rights be extended to prisoners with benchmark disabilities. It was further directed that all States and Union Territories shall file comprehensive compliance reports within the stipulated period, clearly indicating the measures undertaken for effectuating the directions issued in L. Muruganantham (supra) as well as those mandated vide order dated 2nd December, 2025 in the present proceedings. The relevant extracts from the said order are reproduced hereinbelow: -

“9. We have considered the above submissions advanced by Mr. Kaleeswaram Raj, learned counsel representing the petitioner. Learned counsel for the Union of India and respective States do not object to the inclusion of more directions in addition to those already given in L. Muruganantham (supra).

10. In view of the aforesaid discussion, we hereby direct that, in addition to the salutary directions set out in L. Muruganantham (supra), the following directions shall also be read in conjunction with the mandate of the said judgment: -

A. The directions issued by this Court in L. Muruganantham (supra) shall be extended to all the States and the Union Territories, to ensure that the principles are adopted mutatis mutandis within their prison systems as well.

B. Every State and Union Territories