Supreme Court upholds Rs.5 lakh compensation for disabled inmate and issues detailed prison‑reform directions for persons with disabilities

A bench of Justices R. Mahadevan and J.B. Pardiwala heard an appeal by L. Muruganantham challenging the Madras High Court’s judgment which had enhanced compensation awarded by the State Human Rights Commission and issued directions for implementation of the Rights of Persons with Disabilities Act, 2016 in relation to police and prison functioning. The dispute arose from allegations of illegal arrest, custodial harassment by a police officer and inadequate care during short incarceration of the appellant, a person with progressive locomotive disability.

The Court affirmed the High Court’s core findings and relief. It found no reason to interfere with the High Court’s enhancement of compensation from Rs.1,00,000 to Rs.5,00,000 and its concurrent dismissal of the complaint against prison authorities, while upholding disciplinary and recovery directions against the erring police officer. The Court emphasised the State’s obligation to ensure dignity and accommodations for prisoners with disabilities and issued comprehensive, time‑bound directives on identification, accessibility, healthcare, diet, training, data collection and amendment of prison rules. The Court, in its reasoning, observed: “The State has a constitutional and moral obligation to uphold the rights of prisoners with disabilities. This includes not only ensuring non‑discriminatory treatment but also enabling their effective rehabilitation and reintegration into society. The disabilities of incarcerated individuals must not become a basis for further deprivation or suffering; rather, the prison system must evolve to affirm their rights and provide the care necessary for rehabilitation.” The judgment also recorded that “Prisons are correctional institutions – not extensions of civil society’s comforts,” while noting that Article 21 extended to prisoners and required adequate, medically appropriate care.

Background The appellant, an advocate suffering from Becker Muscular Dystrophy and other conditions, was arrested on 29.02.2020 in relation to an FIR arising from a family dispute. He alleged that the arrest was effected at the behest of his uncle, accompanied by harassment by the arresting officer, and that while in custody at Central Prison, Coimbatore he was denied adequate medical care, physiotherapy, protein‑rich diet and accessible facilities, causing deterioration of his health. The appellant filed SHRC Complaint No.2745/2020 seeking compensation of Rs.50,00,000 and systemic directions; the SHRC awarded Rs.1,00,000, recommended disciplinary action against the police officer and directed prison accessibility measures. Writ petitions followed: the appellant’s W.P. No.22431 of 2021 challenged the SHRC order as inadequate, while the police officer moved W.P. No.22527 of 2021 to quash the SHRC findings.

The High Court partly allowed the petitioner’s writ, enhanced compensation to Rs.5,00,000 (Rs.4,00,000 to be borne by the State), affirmed disciplinary directions against the police officer and directed implementation of sensitisation and CCTV maintenance measures. The State paid Rs.5,25,000 pursuant to G.O.(D) No.270 dated 07.03.2023. On appeal, the Supreme Court found that the arrest and initial treatment amounted to human‑rights violations attributable to the police, but that records showed the appellant had been admitted to the prison hospital during custody and some special amenities were provided; therefore, the court did not find wilful or deliberate neglect by prison authorities warranting further enhancement. The Court cited precedent including Arnesh Kumar v. State of Bihar, Jeeja Ghosh, Vikash Kumar and In re: Inhuman Conditions in 1382 Prisons, and noted systemic deficiencies in prison infrastructure and administration as serious concerns.

The Court therefore issued sweeping directives: identification of prisoners with disabilities at admission; accessible information formats; wheelchair‑friendly infrastructure and accessible toilets; designated physiotherapy and psychotherapy spaces; state‑level access audits within six months; healthcare equivalent to community standards; medically appropriate diets; regular training and sensitisation of prison staff; amendment of prison manuals within six months to align with the RPwD Act and UNCRPD; appointment and strengthening of boards of visitors; maintenance of disaggregated disability data; periodic inspections and a compliance report to the State Human Rights Commission within three months. The appeal was disposed of with no costs.

Case Details: Case No.: Civil Appeal No. 9487 of 2025 (Arising out of SLP (C) No. 1785 of 2023) Case Title: L. Muruganantham v. State of Tamil Nadu & Others Appearances: For the Petitioner(s): L. Muruganantham (party‑in‑person) For the Respondent(s): State Counsel (for State of Tamil Nadu and others)