Denial of Basic Prison Care to Disabled Violates Fundamental Rights: SC | 21 Jul 2025

Source: HT 

Why in News? 

The Supreme Court (SC) of India, in L Muruganantham vs. State of Tamil Nadu Case (2025), ruled that denying prisoners with disabilities essential facilities in prisons violates their fundamental rights.  

• It also emphasised reforms to align with the Rights of Persons with Disabilities Act, 2016 (RPwD Act), to ensure dignity and care for disabled inmates in prisons. 

How do Structural Barriers Exacerbate the Marginalization of Disabled Inmates? 

• Institutional Inaccessibility: Most prison facilities are structurally inaccessible to individuals with mobility, sensory, or cognitive impairments.  
  • The absence of trained caregivers or proper custodial policies has led to denial of daily care—such as assistance with bathing, eating, and dressing—further exacerbating the suffering of disabled prisoners. 
  • Social exclusion faced in free society is intensified in custody due to bureaucratic apathy and lack of institutional sensitivity. 
    • The Court emphasized that such inaccessibility violates prisoners’ fundamental rights, including their dignity under Article 21 of the Indian Constitution. 
• Procedural Discrimination: Lack of interpreters, sign language facilitators, and accessible formats in trial proceedings deny fair hearing. 
  • Absence of assistive technologies, caregivers, or communication aids was deemed as “indirect discrimination.’’ 
• Neglect of Therapeutic Needs: Absence of dedicated physiotherapy, psychotherapy, or psychiatric care facilities in jails leads to avoidable deterioration of health. 
• Data Gaps: NCRB does not record disability status of prisoners, hampering policy design and targeted intervention. 
• Violation of RPwD Act, 2016: The SC’s judgment highlights breaches of Sections 6, 25, and 38 of the Rights of Persons with Disabilities (RPwD) Act, 2016, which mandate accessible infrastructure and reasonable accommodations in institutions, including prisons. 
  • The Court criticized prison manuals as outdated and not compliant with RPwD Act, 2016 or prior judicial pronouncements. 

What are the Constitutional and Legal Rights of PWDs in Custodial Settings? 

• Fundamental Rights Violations: Article 14 (Equality before law) and Article 21 (Right to life and personal liberty) are directly infringed when basic care is denied. 
  • The Court affirmed that incarceration does not justify the denial of dignity, humane treatment, or necessary accommodations. 
• RPwD Act, 2016 Provisions: 
  • Section 6: Protection and safety in situations of risk, including custodial settings. 
  • Section 25: Access to healthcare, including preventive and rehabilitative services. 
  • Section 38: Mandates equal opportunity in all public services including law enforcement and justice systems. 
• International Commitments: Article 15 of the United Nations Convention on Rights of Persons with Disabilities (UNCRPD), to which India is a signatory, prohibits any cruel, inhuman, or degrading treatment of disabled persons in detention.

What are the SC’s Key Directives for Making Prisons Disabled-Friendly? 

• Identification of Prisoners with Disabilities: Prison authorities must promptly identify prisoners with disabilities at admission, allowing them to declare their condition and specific needs. 
• Universal Accessibility: Rules and essential prison information must be provided in accessible formats like Braille, large print, sign language, or simplified language, ensuring universal accessibility. 
  • Prisons must have wheelchair-friendly spaces, accessible toilets, and ramps to ensure universal accessibility. 
• Therapeutic Facilities: All prisons must have dedicated spaces for physiotherapy, psychotherapy, and other essential therapeutic services. 
• Access Audit: A State-level access audit of all prisons in Tamil Nadu must be completed within six months by an expert committee including officials from the Social Welfare Department, the Department for the Welfare of Differently Abled Persons, and certified access auditors. 
• Training and Sensitization of Prison Officials: Prison staff should undergo training and sensitization on the needs of prisoners with disabilities to promote a compassionate and informed approach. 

Conclusion 

The Supreme Court’s ruling in L Muruganantham vs. State of Tamil Nadu Case (2025) marks a significant step towards inclusive prison reform. By enforcing the RPwD Act and aligning with constitutional and international standards, the judgment reinforces dignity, accessibility, and humane treatment for prisoners with disabilities, ensuring their fundamental rights are protected.