'Lawful incarceration doesn't suspend right to dignity', says Supreme Court for disabled-friendly prisons

New Delhi: The Supreme Court on Tuesday said that lawful incarceration does not suspend the right to human dignity, as it directed jail authorities of Tamil Nadu to identify prisoners with disabilities at the time of admission and equip all prisons with disability-friendly infrastructure.

A bench of Justices J B Pardiwala and R Mahadevan said the punishment handed down to a convict lies only in the restriction of liberty, not in the denial of humane treatment or reasonable accommodations.

"Failure to meet the obligations by the state authorities inflicts disproportionate suffering on disabled prisoners and betrays the constitutional role of the state as a custodian, not a tormentor, of those it detains," the court said.

The bench said 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.

The court found most state prison manuals remain outdated and uninformed by developments in disability law and rights-based discourse.

"They frequently conflate sensory or physical disabilities with mental illness or cognitive decline, thereby eroding the distinct legal right to reasonable accommodation. This conflation promotes harmful stereotypes and obstructs disabled inmates from claiming their lawful entitlements," Justice Mahadevan wrote in the 46-page judgment on behalf of the bench.

The apex court said prison authorities are under a duty to coordinate with public healthcare systems to ensure uninterrupted care, and logistical or financial limitations cannot be cited to justify a withdrawal of this obligation.

The bench, however, said, while persons with disabilities constitute 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 bench said 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 must ensure that every inmate, including those with disabilities, receives adequate, nutritious, and medically appropriate food, subject to medical certification," the bench said.

The court ordered that each prisoner should be allowed to declare any disability and provide information about their specific needs. All prison premises shall be equipped with wheelchair-friendly spaces, accessible toilets, ramps, and sensory-safe environments to ensure universal accessibility. All prisons shall designate and maintain dedicated spaces for physiotherapy, psychotherapy, and other necessary therapeutic services, the court said.

A plea was filed by advocate L Muruganantham, who suffered from Becker muscular dystrophy. The advocate moved against an order of the Madras High Court for Rs 5 lakh compensation to him. He was imprisoned on a criminal complaint of a person with whom his family had a land dispute.

The apex court directed a state-level access audit of all prisons in Tamil Nadu to be completed within six months by an expert committee comprising officials from the Social Welfare Department, Department for the Welfare of Differently-Abled Persons and certified access auditors. "Periodic audits shall thereafter be conducted and updated regularly by the Harmonised Guidelines and Standards for Universal Accessibility in India (2021)," the bench said.

It stated that the State Prison Manual should be reviewed and appropriately amended within six months to ensure conformity with the RPwD Act, 2016 and the United Nations Convention on the Rights of Persons with Disabilities, 2006 (UNCRPD).

The Director General of Prisons was also instructed to file a comprehensive compliance report before the State Human Rights Commission (SHRC) within three months from the date of the judgment, detailing steps taken in furtherance of these directions.