# L. Muruganantham v. State of Tamil Nadu & Others

- **Citation:** 2025 INSC 844
- **Court:** Supreme Court of India
- **Decided:** 2025-07-15
- **Case number:** Civil Appeal No. 9487 of 2025
- **Bench:** J.B. Pardiwala, R. Mahadevan
- **Source:** https://unisonlegal.in/judgment/supreme-court-of-india/l-muruganantham-v-state-of-tamil-nadu-others-38583
- **Pages:** 49

## Headnote

(A) Whether the order of the High Court enhancing compensation
to Rs.5,00,000/- for the alleged violations committed against the
appellant, while dismissing the complaint against respondent no.3,
and partly allowing the complaint against respondent no.2, calls
for interference by this Court; and (B) Whether adequate and
appropriate facilities are being made available to prisoners with
disabilities during incarceration in the prisons of Tamil Nadu, in
compliance with the provisions of the RPwD Act, 2016 and UNCPRD.
Headnotes†
Constitution of India - Arts.14 and 21 - Rights of Persons
with Disabilities Act, 2016 - United Nations Convention on
the Rights of Persons with Disabilities, 2006 - Prisoners with
disabilities - Appellant herein suffers from Becker Muscular
Dystrophy, Autism Spectrum Disorder, and associated
psychological conditions - An FIR was filed against him -
Appellant was arrested - 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 - Consequently, he lodged a complaint before the
SHRC - The SHRC awarded Rs.1,00,000/- as compensation and
directed initiation of disciplinary proceedings against erring
police officer-respondent no.2 - The High Court enhanced
the compensation to Rs.5,00,000/- and awarded costs of
Rs.25,000/- to the appellant - The direction for disciplinary
action against respondent no.2, was affirmed by the High
Court and complaint against respondent no.3 (the prison
authorities) was dismissed - Whether the order passed by
the High Court require interference:
* Author
936
[2025] 7 S.C.R.
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Held: 1. The deficiencies in prison facilities may not be directly
attributable to the respondent authorities in the present case -
Accordingly, they cannot be held liable for the same - The direction
issued by the High Court for initiation of departmental proceedings
against respondent no.2, as well as the dismissal of the complaint
against respondent no.3 (the prison authorities), appears to be
well-reasoned and based on a careful appreciation of the facts and
evidence on record - In contrast, no material was produced by
the appellant to establish wilful negligence or deliberate omission
on the part of the prison authorities to warrant a finding of human
rights violation - There is no justification to disturb conclusions
reached by the High Court. [Para 22]
2. 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 - 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 - Mere non-supply of preferred or costly food
items cannot ipso facto be treated as a violation of fundamental
rights - Prisons are correctional institutions-not extensions of civil
society's comforts - The non-supply of non-essential or indulgent
items does not amount to a constitutional or human rights violation
unless it results in demonstrable harm to health or dignity -
Considering the nature of the appellant's disability (assessed at
80%), the progressive deterioration of his health during custody,
the High Court was justified in enhancing the compensation from
Rs.1,00,000/- to Rs.5,00,000/-. [Paras 21.1, 21.2, 21.3]
Prison Reforms - Urgent need - Improvement of quality of
life of inmates - Discussed.
Rights of Prisoners with disabilities - Obligation of the State:
Held: The State has a constitutional and moral obligation to
uphold the rights of prisoners with disabilities - This includes not
only ensur

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[2025] 7 S.C.R. 935 : 2025 INSC 844
L. Muruganantham
v.
State of Tamil Nadu & Others
(Civil Appeal No. 9487 of 2025)
15 July 2025
[J.B. Pardiwala and R. Mahadevan,* JJ.]
Issue for Consideration
(A) Whether the order of the High Court enhancing compensation
to Rs.5,00,000/- for the alleged violations committed against the
appellant, while dismissing the complaint against respondent no.3,
and partly allowing the complaint against respondent no.2, calls
for interference by this Court; and (B) Whether adequate and
appropriate facilities are being made available to prisoners with
disabilities during incarceration in the prisons of Tamil Nadu, in
compliance with the provisions of the RPwD Act, 2016 and UNCPRD.
Headnotes†
Constitution of India - Arts.14 and 21 - Rights of Persons
with Disabilities Act, 2016 - United Nations Convention on
the Rights of Persons with Disabilities, 2006 - Prisoners with
disabilities - Appellant herein suffers from Becker Muscular
Dystrophy, Autism Spectrum Disorder, and associated
psychological conditions - An FIR was filed against him -
Appellant was arrested - 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 - Consequently, he lodged a complaint before the
SHRC - The SHRC awarded Rs.1,00,000/- as compensation and
directed initiation of disciplinary proceedings against erring
police officer-respondent no.2 - The High Court enhanced
the compensation to Rs.5,00,000/- and awarded costs of
Rs.25,000/- to the appellant - The direction for disciplinary
action against respondent no.2, was affirmed by the High
Court and complaint against respondent no.3 (the prison
authorities) was dismissed - Whether the order passed by
the High Court require interference:
* Author
936
[2025] 7 S.C.R.
Supreme Court Reports
Held: 1. The deficiencies in prison facilities may not be directly
attributable to the respondent authorities in the present case -
Accordingly, they cannot be held liable for the same - The direction
issued by the High Court for initiation of departmental proceedings
against respondent no.2, as well as the dismissal of the complaint
against respondent no.3 (the prison authorities), appears to be
well-reasoned and based on a careful appreciation of the facts and
evidence on record - In contrast, no material was produced by
the appellant to establish wilful negligence or deliberate omission
on the part of the prison authorities to warrant a finding of human
rights violation - There is no justification to disturb conclusions
reached by the High Court. [Para 22]
2. 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 - 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 - Mere non-supply of preferred or costly food
items cannot ipso facto be treated as a violation of fundamental
rights - Prisons are correctional institutions-not extensions of civil
society's comforts - The non-supply of non-essential or indulgent
items does not amount to a constitutional or human rights violation
unless it results in demonstrable harm to health or dignity -
Considering the nature of the appellant's disability (assessed at
80%), the progressive deterioration of his health during custody,
the High Court was justified in enhancing the compensation from
Rs.1,00,000/- to Rs.5,00,000/-. [Paras 21.1, 21.2, 21.3]
Prison Reforms - Urgent need - Improvement of quality of
life of inmates - Discussed.
Rights of Prisoners with disabilities - Obligation of the State:
Held: 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 - This Court
emphasizes that reasonable accommodations are not optional,
but integral to any humane and just carceral system - A systemic
transformation is urgently required-one grounded in compassion,
[2025] 7 S.C.R.
937
L. Muruganantham v. State of Tamil Nadu & Others
accountability, and a firm constitutional commitment to dignity
and equality - 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. [Para 34]
Constitution of India - Arts. 14 and 21 - Rights of Persons
with Disabilities Act, 2016 - United Nations Convention on
the Rights of Persons with Disabilities, 2006 - Prisoners with
disabilities - The following directions are issued for immediate
and time-bound compliance:
Held: 1) All prison authorities shall promptly identify prisoners with
disabilities at the time of admission - All rules, regulations, and
essential information about prison life shall be provided to such
prisoners in accessible and understandable formats (e.g., Braille,
large print, sign language, or simplified language); 2) All prison
premises shall be equipped with wheelchair-friendly spaces,
accessible toilets, ramps, and sensory-safe environments to ensure
universal accessibility; 3) All prisons shall designate and maintain
dedicated spaces for physiotherapy, psychotherapy and other
necessary therapeutic services; 4) A State-level access audit of
all prisons in Tamil Nadu to be conducted by an expert committee;
5) The prison authorities shall ensure complete compliance with
Sections 40 and 45 of the RPwD Act, 2016, Rule 15 of the 2017 Rules
and the Harmonized Guidelines, 2021 in all prison infrastructure
and services; 6) The State shall provide healthcare for prisoners
with disabilities equivalent to that available in the community,
including access to physiotherapy, speech therapy, psychiatric
services, and assistive devices (such as wheelchairs, hearing aids,
and crutches); 7) All prison medical officers shall be adequately
trained and sensitized to address disabling conditions, ensuring
provision of appropriate accommodations and treatment without
discrimination or bias; 8) Every prisoner with a disability shall be
provided a nutritious and medically appropriate diet, tailored to their
specific health and dietary needs; 9) Lifesaving treatments, including
regular and need-based physiotherapy and psychotherapy must be
made available on-site or through linkage with government health
facilities; 10) All prison staff shall undergo comprehensive training on
the rights of persons with disabilities; 11) The State Prison Manual
shall be reviewed and appropriately amended within six months to
ensure conformity with the RPwD Act, 2016 and the UNCRPD; 12)
The State shall undertake periodic consultations with civil society
938
[2025] 7 S.C.R.
Supreme Court Reports
organisations working in the disability sector to develop inclusive
policies and identify accommodations based on real needs; 13) The
State shall constitute a monitoring committee to conduct periodic
inspections and submit compliance reports every three months;
14) The State shall maintain and update disaggregated data on
the disability status of prisoners, including records on accessibility,
reasonable accommodations, and medical requirements; 15) The
Director General of Prisons shall file a comprehensive compliance
report before the State Human Rights Commission within three
months from the date of this judgment, detailing all steps taken in
furtherance of these directions. [Para 35]
Case Law Cited
Shri Rama Murthy v. State of Karnataka (1997) 2 SCC
642 - relied on.
Vikash Kumar v. Union Public Service Commission [2021] 12
SCR 311; Jeeja Ghosh v. Union of India [2016] 4 SCR 638;
Re: Inhuman Conditions in 1382 Prisons [2016] 1 SCR 1090;
Arnesh Kumar v. State of Bihar [2014] 8 SCR 128 : (2008) 8 SCC
273 - referred to.
People's Watch v. The Home Secretary, Home Department, Prison
Secretariat and Others (2023) 2 MLJ 478 : CDJ 2023 MHC
025 - approved.
List of Websites
http://www.oics.wa.gov.au/about-oics/independent-visitorservice/; Inspector of Custodial Services Act, 2003 available
at: http://testweb.oics.wa.gov.au/wp-contempt/uploads/2013/11/
Insepctor-of-CustodialServices-Act-2003.pdf; Terms of
Reference available at: https://s3-eu-west-2-amazonaws.com/
ppo-prod-storage-1g9rkhijkjmgw/uploads/2021/12/PPO-2021Terms-of-Reference-with-cover.pdf; http://www/prisons.go.ke/
inspectionsComplainsMonitoringandevaluation.
List of Acts
Rights of Persons with Disabilities Act, 2016; Constitution of India,
1950; United Nations Convention on the Rights of Persons with
Disabilities, 2006; United Nations Standard Minimum Rules for the
Treatment of Prisoners (Nelson Mandela Rules); Rights of Persons
with Disabilities Rules, 2017; Tamil Nadu Prison Rules, 1983.
[2025] 7 S.C.R.
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L. Muruganantham v. State of Tamil Nadu & Others
List of Keywords
Prisoners with disabilities; Article 14 of Constitution; Article 21
of Constitution; Prison Reforms; Becker Muscular Dystrophy;
Autism Spectrum Disorder; Identification of prisoners with
disabilities; Accessibility of prisoners with disabilities; Audit of
prisons; Healthcare for prisoners with disabilities; Accommodation
for prisoners with disabilities; Prison infrastructure and services;
Dietary needs.
Case Arising From
CIVIL APPELLATE JURISDICTION: Civil Appeal No. 9487 of 2025
From the Judgment and Order dated 29.11.2022 of the High Court
of Judicature at Madras in WP No. 22431 of 2021
Appearances for Parties
Advs. for the Respondents:
Amit Anand Tiwari, Sr. A.A.G., Sabarish Subramanian, Ms. Devyani
Gupta, Vishnu Unnikrishnan, Ms. Saushriya Havelia, Ms. Tanvi
Anand, Danish Saifi, Ms. M Karthiga.
Petitioner-in-person.
Judgment / Order of the Supreme Court
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 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
1
Hereinafter referred to as "the High Court"
940
[2025] 7 S.C.R.
Supreme Court Reports
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.
[2025] 7 S.C.R.
941
L. Muruganantham v. State of Tamil Nadu & Others
...
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, and the
same was registered as FIR in Crime No. 108 of 2020 for offences
under Sections 294(b), 323 and 506(ii) of the Indian Penal Code,
18602. Based on the said FIR, the appellant was arrested on
29.02.2020 by Respondent No. 2, who allegedly harassed and tortured
him. He was thereafter, produced before the Judicial Magistrate,
Udumalaipet, who remanded him to judicial custody.
5.
The appellant further alleged that during his incarceration at the
Central Prison, Coimbatore, Respondent No.3 failed to provide
proper food, medical treatment, and care as required under the
Rights of Persons with Disabilities Act, 20163. The prison lacked
infrastructure and facilities necessary for prisoners with disabilities,
2
For short, "IPC"
3
For short, "the RPwD Act, 2016"
942
[2025] 7 S.C.R.
Supreme Court Reports
and the officials were allegedly insensitive and ill-informed regarding
the rights of persons with disabilities. The appellant was released
on bail on 10.03.2020.
6.
Subsequently, the appellant filed a complaint in SHRC No. 2745
of 2020 before the State Human Rights Commission4, seeking
compensation of Rs. 50,00,000/- for the deprivation of life and liberty
during incarceration. He also sought directions for the payment of
Rs.2 crores to the Disability Rights Public Fund under the RPwD
Act, 2016 for violations of his human, fundamental, and statutory
rights, and for action against the erring officials.
7.
After hearing all parties, the SHRC, by order dated 27.08.2021,
disposed of the complaint filed by the appellant, with the following
recommendations:
"(i) The Government of Tamil Nadu shall pay a
compensation of Rs.1,00,000/- (Rupees One Lakh only)
to the Complainant. Thiru L. Muruganantham residing
at No.1/16, Muthu Nagar, Kotapulipalayam Road,
Dharapuram, Tiruppur District, within one month from the
date of receipt of a copy of this Recommendation and the
Government of Tamil Nadu may recover Rs.1,00,000/-
from the 1st Respondent. The complaint against the 2nd
Respondent is dismissed.
(ii) This Commission also recommends to initiate disciplinary
action against the 1st Respondent as per the Rules.
(iii) This Commission further recommends that the
Government of Tamil Nadu to make all the prisons in
the State accessible for persons with disabilities as per
the Rights of Persons with Disabilities Act, 2016 and law
declared by the Hon'ble Supreme Court of India in the
case of Rajiv Raturi vs. Union of India and others on
15.12.2017 which affirmed that "Right to life under Article
21 has been held broad enough to incorporate the right
to accessibility. All Government buildings providing any
services to the public are to be made fully accessible by
June, 2019 which has to be adhered to."
4
For short, "the SHRC"
[2025] 7 S.C.R.
943
L. Muruganantham v. State of Tamil Nadu & Others
8.
Aggrieved by the aforesaid order of the SHRC, the appellant filed
W.P.No.22431 of 2021 before the High Court, seeking a Writ of
Certiorarified Mandamus to call for the records pertaining to SHRC
Case No. 2745 of 2020 dated 27.08 2021, and to quash the same
insofar as it dismissed the complaint against Respondent No.3, failed
to consider the complaint against Respondent No.1, and partially
allowed the complaint against Respondent No.2. The appellant also
sought a direction to Respondent Nos.1 to 3 to pay compensation
of Rs.50,00,000/- for the human rights violations committed against
him, and for directions to Respondent No.1 to implement the RPwD
Act, 2016, and the United Nations Convention on the Rights of
Persons with Disabilities, 20065 in relation to the Police and Prison
Departments in Tamil Nadu.
9.
Respondent No.2, on the other hand, claiming that no human rights
violation was committed against the appellant, and that the SHRC
had erroneously held otherwise, filed W.P.No.22527 of 2021 seeking
to quash the SHRC's order.
10. The High Court, by the common order impugned herein, partly allowed
the writ petition filed by the appellant and dismissed the writ petition
filed by Respondent No.2. Aggrieved by the same, the appellant has
preferred the present appeal before this Court.
11. During the course of hearing, the appellant, appearing as a partyin-person, made the following submissions:
11.1. That the appellant and his aged mother were falsely implicated
in a criminal case lodged at the behest of his paternal uncle
through one Selvakumar. Respondent No.2, acting in collusion
with the said uncle, arrested the appellant illegally and obtained
remand on the basis of false and misleading representations.
The ulterior motive behind this was to coerce the appellant
into transferring his valuable properties to his uncle. Though
a charge sheet was filed, it was ultimately quashed by the
High Court.
11.2. That the appellant suffers from Becker Muscular Dystrophy,
Autism Spectrum Disorder, and associated psychological
conditions. During incarceration, he was denied essential
5
For short, "the UNCRPD"
944
[2025] 7 S.C.R.
Supreme Court Reports
support such as physiotherapy, psychotherapy, protein-rich
nutrition (e.g., eggs, chicken, nuts), accessible sanitation
facilities, ramps, a low sensory environment for rest, and warm
water for bathing. This lack of accommodation caused further
deterioration of his physical and mental health, as evidenced by
undisputed medical records showing his disability progressed
from 70% in 2013 to 80% in 2020.
11.3. That the appellant repeatedly informed prison and medical
authorities of his health condition, yet no physiotherapy or
psychotherapy was provided. Protein-rich foods were denied,
and milk was supplied on only 7 out of 10 days. The prison
lacked accessible toilets and ramps, including in the dispensary.
Loud announcements and continuous lighting aggravated
his sensory distress. The hostile environment worsened
his Avoidant / Restrictive Food Intake Disorder (ARFID), a
condition recognized under DSM-5, leading to further mental
and physical deterioration.
11.4. That both the SHRC and the High Court concurrently found
that Respondent No.2, despite being aware of the appellant's
disability, acted in a callous and inhumane manner with
ulterior motives. The High Court further observed that during
incarceration, the appellant was denied proper medical care,
food, and basic amenities, amounting to a violation of his
statutory rights. Such deprivation, according to the appellant,
constitutes a human rights violation under Section 2(d) of the
Protection of Human Rights Act, 1993, the RPwD Act, 2016,
and Articles 14 and 21 of the Constitution of India. However,
the SHRC awarded a meagre sum of Rs.1,00,000/- towards
compensation, which was slightly enhanced to Rs.5,00,000/-
by the High Court.
11.5. That compensation has been granted only for the human rights
violations committed by the police, whereas no compensation
has been granted for the progressive deterioration of the
appellant's disability caused by inhumane prison conditions.
Such deterioration also constitutes a grave violation of his
fundamental and human rights.
11.6. That as a result of the violations suffered, the appellant now
experiences sleep deprivation, chronic pain, ulceration, and
[2025] 7 S.C.R.
945
L. Muruganantham v. State of Tamil Nadu & Others
severe psychological trauma requiring long-term medication
with significant side effects. His deteriorated health has also
diminished his eligibility for advanced gene therapy - costing
over Rs.16 crores - which should be considered while
assessing compensation.
11.7. That Prisons are ill-equipped to provide reasonable
accommodations to persons with disabilities. Despite statutory
mandates under Sections 39 and 47(1)(a) of the RPwD Act,
2016, no sensitization or awareness programmes have been
conducted for prison staff. RTI responses reveal that prison
authorities maintain no data on accessibility, accommodations,
or compliance. Further, there is a failure to publish disabilityrelated statistics, as mandated by Article 31 of the UNCRPD.
11.8. That the existing Prison Manual is non-compliant with the
RPwD Act, 2016, and fails to address the needs of persons with
varying disabilities. In Shri Rama Murthy v. State of Karnataka6,
this Court noted that the outdated Prison Act, 1894, must be
thoroughly overhauled. The appellant submits that systemic
disregard for disability rights has led to irreversible harm to his
health and dignity, and endangers similarly placed prisoners.
11.9. The appellant further relies on the following judicial precedents:
(i)
Vikash Kumar v. Union Public Service Commission7,
where this Court held that Section 3 of the RPwD
Act, 2016, is a statutory embodiment of constitutional
guarantees under Articles 14, 19, and 21, and that denial
of reasonable accommodation constitutes discrimination;
(ii)
Jeeja Ghosh v. Union of India8, which emphasized
adopting a human rights-based approach toward persons
with disabilities;
(iii) Re: Inhuman Conditions in 1382 Prisons9, wherein
this Court reiterated that the right to life under Article
21 includes the right to live with dignity, which applies
equally to prisoners.
6
(1997) 2 SCC 642
7
[2021] 12 SCR 311
8
[2016] 4 SCR 638
9
[2016] 1 SCR 1090
946
[2025] 7 S.C.R.
Supreme Court Reports
11.10. In light of the above facts, documentary evidence, and legal
principles, the appellant prays for compensation and systemic
reforms. The directions sought by the appellant are as follows:
(a) To direct the jail authorities to pay compensation for the
violation of the appellant's rights during his incarceration;
(b) To ensure provision of physiotherapy, psychotherapy,
and all necessary life-saving medical treatments for
prisoners with disabilities;
(c)
To mandate the supply of a proper and nutritious diet
to prisoners with disabilities, tailored to their individual
health needs;
(d) To direct an access audit of all prisons in Tamil Nadu,
in accordance with the Harmonized Guidelines and
Standards for Universal Accessibility in India - 2021;
(e) To mandate full accessibility of prisons in Tamil Nadu
as required under Section 45 read with Section 40 of
the RPwD Act, 2016, Rule 15 of the Rights of Persons
with Disabilities Rules, 2017, and the above Guidelines;
(f)
To ensure provision of reasonable accommodations
under Section 3(5) read with Section 2(h) of the RPwD
Act, 2016, and the principles laid down in Vikash Kumar
(supra);
(g) To conduct sensitization and training programs for prison
authorities, including medical staff, regarding the rights
and needs of prisoners with disabilities, as mandated
under Sections 39 and 47(1)(a) of the RPwD Act, 2016;
(h) To initiate review and amendment of the Prison Manual
under Section 80 of the RPwD Act, 2016, in order to
address and safeguard the rights of prisoners with
disabilities;
(i)
To ensure compliance with Article 31 of the UNCRPD by
maintaining and disseminating disaggregating statistical
data regarding accessibility and accommodations for
prisoners with disabilities on official websites, thereby
ensuring transparency and accountability.
[2025] 7 S.C.R.
947
L. Muruganantham v. State of Tamil Nadu & Others
12. Denying the submissions made by the appellant, the learned counsel
for the respondents submitted as follows:
12.1. In connection with Crime No. 108/2020 registered at
Dharapuram Police Station for offences under Sections 294
(b), 323 and 506(ii) IPC, the appellant was remanded by the
Judicial Magistrate on 29.02.2020 and admitted to Central
Prison, Coimbatore on the same day. He was released on
bail on 10.03.2020. Notably, from the date of admission until
his release, the appellant remained an inpatient in the Prison
Hospital throughout.
12.2. Subsequent to his release, the appellant lodged a complaint
before the SHRC which was registered as Case No.
2475/2020/C2. In this complaint, he alleged custodial torture
by Respondent No.2 during arrest and failure on the part of
Respondent No.3 (prison authorities) to provide basic facilities
and adequate medical treatment, taking into account his
physical disability.
12.3. Upon consideration of the matter, the SHRC awarded
compensation of Rs.1,00,000/- and directed disciplinary
action against the erring police officer (Respondent No.2).
However, it dismissed the complaint against Respondent
No.3. Aggrieved by the limited relief, the appellant filed Writ
Petition No. 22431/21 before the High Court seeking enhanced
compensation of Rs.50,00,000/- and action against the prison
authorities.
12.4. By its order dated 29.11.2022, the High Court partly allowed
the writ petition, observing that while the arrest and initial
treatment of the appellant could amount to a human rights
violation, there was no evidence of any violation by the jail
authorities. The relevant portion of the order is extracted below:
"34...It is seen from the jail records that had been
produced, the petitioner was always in the jail
dispensary and certain special amenities were
provided to him as a physically disabled person.
Special diet which includes milk was supplied to
him. Mere non provision of certain amenities which
would amount to a statutory violation may not strictly
amount of Human Rights violation. While arrest
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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."
12.5.
Nonetheless, the High Court enhanced the compensation
awarded by the SHRC from Rs.1,00,000/- to Rs.5,00,000/ ,
of which Rs.4,00,000/- was to be paid by the State and
Rs.1,00,000/- recovered from Respondent No.2. Additionally,
Rs.25,000/- was awarded as costs to the appellant, payable
by the State. In compliance, the Government issued G.O.(D)
No.270, Home (Police-HR) Department Dated 07.03.2023,
sanctioning Rs.5,25,000/- towards payment of compensation.
Thus, according to the respondents, the order of the High
court has already been complied with.
12.6.
It is relevant to note here that the appellant was continuously
housed as an inpatient in the Prison Hospital from 29.02.2020
to 10.03.2020. This, according to the respondents, indicates
that the prison authorities took necessary steps to address
the appellant's specific needs, including providing a cot with
a mattress, a special medical diet (milk and egg), psychiatric
counselling, and assistance from medical staff and coprisoners for daily routines.
12.7.
As per the medical history recorded on 01.03.2020 by the
Prison Doctor, the appellant was a known case of Becker's
Muscular dystrophy since the age of 27 and had a history
of psychiatric illness, for which he was on anti-depressants.
However, no supporting medical records were produced
by the appellant or his family members at the time of
admission. Based on clinical examination, the Medical Officer
recommended inpatient care, continued physiotherapy,
psychiatric counselling, and a special medical diet.
12.8.
In accordance with Rules 196, 197, 198(iii), and 845 of
the Tamil Nadu Prison Rules, 1983, every new prisoner is
examined by a Medical Officer and may be placed under
quarantine or admitted to the Prison Hospital, if required.
These procedures were duly followed in the appellant's case.
Furthermore, Rule 405 of the Tamil Nadu Prison Manual
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L. Muruganantham v. State of Tamil Nadu & Others
Volume II provides that the medical diet of hospitalized
prisoners is under the full control of the Medical Officer.
Accordingly, the appellant was provided with appropriate
medical attention and dietary support during his period of
incarceration.
12.9.
The respondents submitted that Central and Special Prisons
in Tamil Nadu are equipped with wheelchairs, disabled-friendly
toilets, and trained personnel to attend to the needs of elderly,
sick, and disabled inmates. All such facilities were available
to the appellant. The Medical Officer recorded all relevant
details in the prescribed proforma as per the guidelines issued
by the National Human Rights Commission.
12.10. Ultimately, it was submitted that the prison authorities
extended all possible medical care and basic amenities to
the appellant, and hence, the claim of human rights violations
during his incarceration is unfounded.
12.11. Therefore, the learned counsel submitted that the appeal is
devoid of merit and is liable to be dismissed.
13. In reply, the appellant submitted that the prison records and the counter
affidavit filed by the respondents reveal inconsistencies and false
claims regarding the provision of treatment and accommodations.
For instance, while certain records assert that eggs were supplied,
the prison food logs indicate otherwise. Similarly, psychological
counselling was only recommended, but never actually administered,
contrary to the claims made by the respondents. Thus, according to
the appellant, the respondents failed to comply with the provisions
of the RPwD Act, 2016 and other applicable laws.
14. We have considered the submissions made by the appellant as partyin-person and the learned counsel appearing for the respondents
and carefully perused the materials available on record.
15. The two broad issues that arise for our consideration are as follows:
(A) Whether the order of the High Court enhancing compensation
to Rs.5,00,000/- for the alleged violations committed against the
appellant, while dismissing the complaint against Respondent
No.3, and partly allowing the complaint against Respondent
No.2, calls for interference by this Court; and
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(B) Whether adequate and appropriate facilities are being made
available to prisoners with disabilities during incarceration in
the prisons of Tamil Nadu, in compliance with the provisions
of the RPwD Act, 2016 and UNCPRD.
Order of the High Court
16. 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. Though an
FIR was registered and a charge sheet was filed pursuant thereto,
the same was eventually quashed by the High Court. However, by
that time, the appellant had already undergone incarceration from
29.02.2020 to 10.03.2020.
17. 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. Consequently, he lodged
a complaint before the SHRC seeking compensation and initiation of
actions against the erring officials for the alleged violations committed
against him. The respondents, however, contended that the appellant
was housed in the prison hospital throughout his custody, and was
provided with food, treatment, and care suited to his needs, and
therefore, no human rights violation could be attributable to the
prison authorities.
18. Upon a detailed examination of the records, 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 Bihar10. However, it
held that during the period of incarceration, the appellant had been
admitted to the prison hospital and was provided necessary medical
treatment. Consequently, the SHRC found no specific human rights
violation attributable to the prison authorities during the appellant's
custody. Accordingly, in the complaint filed by the appellant, the SHRC
recommended the payment of compensation of Rs. 1,00,000/- to
the appellant, to be paid by Respondent No.1 and recoverable from
Respondent No.2. It also recommended initiation of departmental
disciplinary proceedings against Respondent No.2.
10
(2014) 8 SCC 273
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951
L. Muruganantham v. State of Tamil Nadu & Others
19. A similar view was taken by the High Court in the writ petition filed by the
appellant. However, pointing out that the compensation awarded by the
SHRC was inadequate given the nature and circumstances of the case,
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 by the High Court. Additionally, the High
Court awarded costs of Rs.25,000/- to the appellant payable by the
State. At this juncture, it is relevant to note 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.
20. 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. 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. These findings are supported by
documentary evidence, and we find no reason to depart from them.
21. The next issue to be determined is whether the compensation
of Rs.1,00,000/- awarded by the SHRC, and later enhanced to
Rs.5,00,000/- by the High Court, merits further enhancement by
this Court.
21.1. 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. 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. Hence, these
shortcomings do not amount, per se, to a violation of human
rights attributable to the jail authorities.
21.2. The appellant specifically contended that he was not provided
with adequate protein-rich food, such as eggs, chicken and
nuts, on a daily basis. While persons with disabilities constitute
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a particularly vulnerable class and are entitled to reasonable
accommodations under domestic law and international
conventions, the mere non-supply of preferred or costly food
items cannot ipso facto be treated as a violation of fundamental
rights. The right to life under Article 21 of the Constitution
undoubtedly extends to all prisoners, including those with
disabilities. However, this does not confer a right to demand
personalised or luxurious food choices. 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.
21.3. Prisons are correctional institutions - not extensions of civil
society's comforts. The non-supply of non-essential or indulgent
items does not amount to a constitutional or human rights
violation unless it results in demonstrable harm to health or
dignity. 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/-. 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.
22. As already indicated, the deficiencies in prison facilities may not be
directly attributable to the respondent authorities in the present case.
Accordingly, they cannot be held liable for the same. The direction
issued by the High Court for initiation of departmental proceedings
against Respondent No.2, as well as the dismissal of the complaint
against Respondent No.3 (the prison authorities), appears to be
well-reasoned and based on a careful appreciation of the facts
and evidence on record. In contrast, no material was produced by
the appellant to establish wilful negligence or deliberate omission
on the part of the prison authorities to warrant a finding of human
rights violation. Therefore, we find no justification to disturb these
conclusions reached by the High Court.
Adequate and Appropriate facilities for prisoners with disabilities
23. Prisons are often regarded as the "tail-end" of the criminal justice
system - historically designed for rigid discipline, harsh conditions,
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L. Muruganantham v. State of Tamil Nadu & Others
and minimal liberties. 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.
24. In the present case, 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. This Court is conscious
of the systemic neglect in prison infrastructure, especially in relation
to the needs of prisoners with disabilities. In Rama Murthy (supra),
this Court referred to the Mulla Committee Report and emphasised
the dire conditions in Indian prisons, including inadequate hygiene,
insufficient medical care, and lack of accountability.