State Must Uphold Rights Of Prisoners With Disabilities | Supreme Court Issues Binding Directives To Tamil Nadu For Disability-Compliant Prisons And Police Sensitization
Kiran Raj
The Supreme Court Division Bench of Justice J.B. Pardiwala and Justice R. Mahadevan has disposed of a civil appeal arising from a dispute over inadequate treatment and compensation following the wrongful incarceration of a person with disabilities. The Court upheld the High Court’s direction enhancing the compensation awarded by the State Human Rights Commission and further issued a series of binding directives to the State of Tamil Nadu. The directives pertain to compliance with the Rights of Persons with Disabilities Act, 2016, and ensuring systemic reforms in prison conditions for differently abled inmates. The Bench instructed the Government to conduct access audits, introduce prison infrastructure reforms, implement disability awareness programmes, and ensure compliance reporting. It also directed measures to ensure the effective functioning of CCTV cameras in police stations and institutionalized police and medical officer sensitization.
The matter arose from a series of complaints and legal proceedings initiated by an individual with a diagnosed locomotor disability who was arrested and incarcerated in connection with a criminal complaint in the State of Tamil Nadu. The appellant, an advocate suffering from Becker Muscular Dystrophy—a progressively degenerative locomotor condition—was initially certified with 70% disability in 2013, which escalated to 80% by 2020. He additionally alleged suffering from autism and associated psychological illnesses.
The appellant claimed that a false and malicious complaint was lodged against him and his elderly mother by one Selvakumar, purportedly acting on behalf of his paternal uncle. This complaint was registered as FIR No. 108 of 2020 under Sections 294(b), 323, and 506(ii) of the Indian Penal Code, 1860. Based on this complaint, the appellant was arrested by Respondent No. 2 on 29.02.2020 and subsequently remanded to judicial custody by the Judicial Magistrate, Udumalaipet.
While in custody at the Central Prison, Coimbatore, the appellant contended that prison authorities, particularly Respondent No. 3, failed to provide essential medical care, dietary requirements, and necessary accommodations as mandated under the Rights of Persons with Disabilities Act, 2016 (hereinafter “the RPwD Act”). The appellant was granted bail and released from custody on 10.03.2020.
Subsequently, the appellant approached the State Human Rights Commission (SHRC) by filing Case No. 2745 of 2020. He sought a compensation of Rs. 50,00,000 for the alleged deprivation of life and liberty, and a further sum of Rs. 2 crores to be paid to the Disability Rights Public Fund under the RPwD Act for systemic violations. The appellant also requested punitive and disciplinary action against the erring police and prison officials.
After hearing all parties, the SHRC issued its order dated 27.08.2021, wherein it directed the State of Tamil Nadu to pay Rs. 1,00,000 to the appellant and to recover the said amount from Respondent No. 2. It also recommended the initiation of disciplinary proceedings against Respondent No. 2. The complaint against Respondent No. 3 was dismissed. Further, the SHRC directed the State to ensure that all prisons were made accessible in accordance with the RPwD Act and the decision in Rajiv Raturi v. Union of India & Ors., dated 15.12.2017, which affirmed the right to accessibility under Article 21 of the Constitution.
Dissatisfied with the limited relief granted by the SHRC, the appellant filed Writ Petition No. 22431 of 2021 before the High Court of Madras. The petitioner challenged the dismissal of claims against Respondent No. 3, as well as the limited nature of relief granted in respect of Respondent No. 2. He reiterated that compensation should have been awarded for the progressive deterioration of his health and rights violations by prison authorities, in addition to the illegal arrest.
Respondent No. 2, in turn, filed Writ Petition No. 22527 of 2021 seeking to quash the SHRC order, denying allegations of custodial torture or unlawful arrest.
The High Court disposed of both writ petitions through a common order dated 29.11.2022. It partly allowed W.P. No. 22431 of 2021, enhancing compensation to Rs. 5,00,000—of which Rs. 4,00,000 was to be borne by the State and Rs. 1,00,000 recoverable from Respondent No. 2. The writ petition filed by Respondent No. 2 was dismissed. The Court also imposed a cost of Rs. 25,000 to be paid to the appellant by the State. However, it upheld the dismissal of claims against the prison authorities and found no specific human rights violations attributable to them.
Aggrieved by the High Court’s refusal to grant further compensation and its exoneration of Respondent No. 3, the appellant approached the Supreme Court by filing Civil Appeal No. 9487 of 2025.
During the proceedings before the Supreme Court, the appellant, appearing in person, submitted that he was subjected to arrest under fabricated charges and was remanded to custody due to collusion between Respondent No. 2 and his paternal uncle. He alleged that the arrest was made with the intent to forcibly transfer property and that his disability and associated medical needs were disregarded. He claimed deprivation of physiotherapy, psychotherapy, protein-rich diet, and access to sanitary facilities during his incarceration, resulting in irreversible physical and psychological deterioration.
The appellant also submitted that his existing Avoidant/Restrictive Food Intake Disorder (ARFID), a DSM-5 recognized condition, was aggravated by the prison environment. He emphasized that the prison’s failure to provide accessible infrastructure constituted a violation of Articles 14 and 21 of the Constitution, the RPwD Act, and the United Nations Convention on the Rights of Persons with Disabilities, 2006 (UNCRPD).
The appellant further contended that prisons in Tamil Nadu lacked compliance with Sections 39 and 47(1)(a) of the RPwD Act, particularly regarding sensitization of prison personnel and publication of disability statistics. He cited RTI responses revealing that the authorities maintained no relevant data on accessibility or accommodations, in contravention of Article 31 of the UNCRPD. He argued that the Tamil Nadu Prison Manual was outdated and failed to meet the statutory requirements laid out in the RPwD Act. Citing precedents such as Vikash Kumar v. UPSC and Jeeja Ghosh v. Union of India, he demanded systemic prison reforms, including reasonable accommodations, access audits, and amendments to prison rules.
The respondents, through learned counsel, opposed the appeal. They asserted that the appellant was detained following due process and remained an inpatient at the prison hospital during his entire incarceration from 29.02.2020 to 10.03.2020. They claimed the appellant was provided with special dietary items such as milk and eggs, psychiatric counselling, and assistance with daily routines. The respondents submitted that the compensation awarded by the High Court had been paid in full and that the matter warranted no further judicial intervention.
The Supreme Court thereafter considered the appeal on two primary issues: (1) whether the High Court’s enhancement of compensation and its findings warranted interference; and (2) whether Tamil Nadu prisons complied with the RPwD Act in relation to prisoners with disabilities.
The Supreme Court considered two primary issues: the adequacy of the compensation awarded by the High Court and the compliance of prison infrastructure in Tamil Nadu with statutory obligations under the Rights of Persons with Disabilities Act, 2016.
In addressing the factual foundation of the appeal, the Court recorded, “It is not in dispute that the appellant was falsely implicated in a criminal case at the behest of his paternal uncle, resulting in his illegal arrest and subsequent harassment by Respondent No.2.” The Court further noted, “Though an FIR was registered and a charge sheet was filed pursuant thereto, the same was eventually quashed by the High Court.”
The Court affirmed the appellant’s incarceration from 29.02.2020 to 10.03.2020 and evaluated whether the treatment during this period amounted to human rights violations. It observed, “According to the appellant, during his incarceration, the prison authorities failed to provide him with appropriate food, medical care, and other necessary support considering his physical disability, which led to a deterioration in his health.”
The Court referenced the SHRC's findings and held, “The SHRC concluded that the appellant’s arrest was in clear violation of the guidelines laid down by this Court in Arnesh Kumar v. State of Bihar.” However, the SHRC had not found any human rights violations attributable to the prison authorities. The High Court had similarly held that “while the arrest and incarceration of the petitioner could be said to be a Human Rights Violation, the non-provision of certain amenities or treatment during a short period of incarceration, in our opinion, will not amount to a serious Human Rights violation.”
Addressing the enhancement of compensation, the Supreme Court recorded, “The High Court enhanced the compensation to Rs.5,00,000/-, directing that Rs.4,00,000/- be paid by the Government. The other directions of the SHRC including the imposition of penalty of Rs.1,00,000/- on Respondent No.2 and the recommendation for disciplinary action against him, were affirmed.” It noted that “the respondents have complied with the directions of the High Court and have paid the entire amount of Rs.5,25,000/- to the appellant.”
The Court acknowledged that “both the SHRC and the High Court unequivocally held that the FIR, arrest, and incarceration of the appellant were carried out at the behest of his paternal uncle with the ulterior motive of usurping his property.” It added, “The arrest was illegal and did not comply with the safeguards prescribed by this Court. Importantly, the authorities failed to consider the appellant’s disability status.”
On the question of whether the compensation should be further enhanced, the Bench held:
“While it is evident that the appellant did not receive certain medical and dietary facilities appropriate to his condition during incarceration, the records indicate that he remained in the prison hospital throughout and was provided with some special amenities recognising his disability.” It reasoned, “The absence of specific provisions, such as protein-rich food or specialised medical interventions appears to stem from institutional limitations within the prison system rather than from any deliberate neglect or malice on the part of the prison authorities.”
Further, the Court held, “The mere non-supply of preferred or costly food items cannot ipso facto be treated as a violation of fundamental rights.” It added that “the State’s obligation is to ensure that every inmate, including those with disabilities, receives adequate, nutritious, and medically appropriate food, subject to medical certification.”
In its assessment, the Court stated, “Considering the nature of the appellant’s disability (assessed at 80%), the progressive deterioration of his health during custody, and the ongoing treatment he requires, the High Court was justified in enhancing the compensation from Rs.1,00,000/- to Rs.5,00,000/-.” The Bench concluded, “We find this amount to be fair, just, and reasonable in the facts and circumstances of the case, and therefore, see no reason to interfere with the same.”
On the issue of prison infrastructure, the Bench observed, “Prisons are often regarded as the ‘tail-end’ of the criminal justice system – historically designed for rigid discipline, harsh conditions, and minimal liberties.” It noted that, “While modern penological principles advocate rehabilitation over retribution, the current prison infrastructure and operational systems in India remain grossly inadequate – especially when it comes to meeting the needs of prisoners with disabilities.”
It stated, “Though the deficiencies in prison facilities may not be directly attributable to the respondent authorities, they highlight the urgent need for prison reforms, particularly the implementation of disability-sensitive infrastructure and protocols.”
The Court recorded its concern, stating, “Persons with disabilities must be provided healthcare equivalent to that available in the general community. This includes access to physiotherapy, speech therapy, psychiatric care, and assistive devices.” It cautioned, “Logistical or financial limitations cannot be cited to justify a withdrawal of this obligation.”
The Bench underscored India’s obligations under international law, stating, “The United Nations Standard Minimum Rules for the Treatment of Prisoners (Nelson Mandela Rules) prescribe prompt, adequate healthcare and specific attention to the needs of prisoners with disabilities.” It noted that “under Rule 5(2), reasonable accommodations must be made so that persons with disabilities have full and effective access to prison life on an equal basis with others.”
Finally, the Court remarked, “Lawful incarceration does not suspend the right to human dignity. The punishment lies only in the restriction of liberty – not in the denial of humane treatment or reasonable accommodations.” It held that “the lack of a disability-sensitive policy, infrastructure, and data collection systems continues to violate the rights of disabled prisoners and hinders meaningful reform.”
The Supreme Court, upon dismissing the civil appeal, issued a comprehensive set of binding directions to the State of Tamil Nadu, particularly to its Home Department and Police authorities, aimed at ensuring compliance with the Rights of Persons with Disabilities Act, 2016, as well as reinforcing accountability in custodial institutions.
The Court directed the Additional Chief Secretary to Government of Tamil Nadu, Home Department, to conduct district-wise sensitization programmes for Police Officers, including Constables, regarding the Rights of Persons with Disabilities. These programmes are to be specifically designed to provide detailed knowledge on the provisions of the RPwD Act, 2016, and the legislative intention behind its enactment. The sensitization must be directed toward improving police understanding of the dignity, rights, and protections afforded to individuals with disabilities, especially those who come into conflict with the law. The Court further directed that clear guidelines be issued to Police Officers on how physically disabled persons must be handled by law enforcement personnel.
In addition to the directives concerning police personnel, the Supreme Court also instructed that similar guidelines be issued to Government Doctors who examine physically disabled persons brought before them during any phase of the legal process. These guidelines are to ensure that medical practitioners, too, are adequately trained and informed regarding the needs and legal rights of such individuals. The Court emphasized that such protocols are not discretionary but flow directly from the statutory duties created under the RPwD Act, 2016. The Court reiterated, “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.”
In a separate direction focused on custodial surveillance and institutional accountability, the Court ordered the Director General of Police, Tamil Nadu, to implement a mechanism for the regular inspection of CCTV cameras installed in all police stations across the State. The Court mandated that a District Level Officer be appointed and made in-charge of ensuring the functioning of CCTV cameras in designated police stations within each district. This officer is to be held personally accountable for any failure to maintain operational cameras. The Court stated that the failure to ensure CCTV functionality would henceforth be viewed seriously, and that the presence of functioning surveillance systems is central to transparency and trust in law enforcement agencies.
The Court concluded that these directives must be implemented in full and stated, “We hope that the above directions would be complied with in their letter and spirit in the interest of the Police Force itself.” The connected miscellaneous petition was ordered to stand closed accordingly.
The Supreme Court, while dismissing the appeal, issued a series of directions aimed at institutional reform and statutory compliance. These directives were framed in the context of the Rights of Persons with Disabilities Act, 2016 and other applicable standards and were addressed primarily to the State Government of Tamil Nadu and its relevant departments.
The Court directed the Additional Chief Secretary to Government of Tamil Nadu, Home Department, to ensure that District-wise sensitization programmes are conducted for Police Officers, including Constables, regarding the Rights of Persons with Disabilities. These programmes are to be designed in a manner that effectively educates police personnel on the provisions of the 2016 enactment and the legislative intent behind its formulation. The Court held that guidelines must also be issued to Police Officers on how to handle physically disabled persons, especially when such individuals are in conflict with the law.
In tandem with police sensitization, the Court directed that similar guidelines are to be issued to Government Doctors who examine physically disabled persons brought before them in legal proceedings. The Bench recorded that such training and protocols are necessary to ensure compliance with the statutory mandate of the RPwD Act, 2016. It stated unequivocally: “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.”
In respect of custodial facilities, the Court directed the Director General of Police to implement periodical inspection of CCTV Cameras installed in all Police Stations across Tamil Nadu. It mandated that a District Level Officer be designated as in-charge for monitoring the functioning of CCTV cameras in a specified number of police stations within each district. The Court emphasized that this officer shall be held accountable for any failure in ensuring the cameras’ functionality. It remarked that such an initiative, if effectively implemented, “will go a long way in curing the malady of non-functioning CCTV Cameras.” The Court expressed the hope that these directions would be complied with “in their letter and spirit in the interest of the Police Force itself.”
In conclusion, the Court noted that the directions issued were necessary not only for safeguarding the rights of persons with disabilities but also for fostering accountability and systemic integrity across law enforcement and custodial institutions. The connected miscellaneous petition was formally closed.
Case Title: L. Muruganantham v. State of Tamil Nadu & Others
Neutral Citation: 2025 INSC 844
Case Number: Civil Appeal No. 9487 of 2025 (Arising out of SLP (C) No. 1785 of 2023)
Bench: Justice J.B. Pardiwala and Justice R. Mahadevan
