Disability rights and a case for prison reform

Earlier this week, the Supreme Court of India delivered a significant and sobering judgement in L. Muruganantham vs. State of Tamil Nadu, shedding light on a deeply troubling reality: the systemic neglect faced by prisoners with disabilities in our criminal justice system.

The case arose from the experience of Muruganantham, an advocate who has muscular dystrophy, autism, and associated psychological conditions. He was, the Court agreed, falsely implicated in a criminal case. The criminal law was set in motion by a henchman of his paternal uncle to usurp his property. The FIR and charge-sheet against him were eventually quashed by the Madras High Court, but the damage to his health, dignity, and sense of justice was already done.

Muruganantham was arrested in 2020 after a malicious complaint and remanded to judicial custody despite his severe disabilities. During his 10-day incarceration, he alleged a denial of adequate medical care, nutrition, accessibility, and basic psychological support. Despite repeated pleas to prison staff, he contended that he was not provided the support, contributing to the deterioration in his disability percentage. Following his release, he sought compensation and systemic reform from the State Human Rights Commission (SHRC), which awarded a compensation amount of Rs 1 lakh. The High Court increased it to Rs 5 lakh; now, the Supreme Court has upheld the enhanced compensation while issuing broader directions for systemic reform.

The Court noted that the petitioner was, indeed, not provided certain medical interventions. That said, he was placed in the prison hospital, and the absence of facilities is attributable to institutional limitations rather than malice on the part of the officials. As to the petitioner’s contention that he was not provided a protein-rich diet, the Court held that prisons are, after all, correctional institutions and cannot be expected to afford all the comforts available in civil society.

India’s prisons remain structurally and operationally ill-equipped to meet the needs of disabled inmates. Lack of accessibility, specialised healthcare, assistive devices, and sensitised staff constitutes a denial of constitutional rights under Article 21. Prison authorities are duty-bound to ensure that inmates with disabilities continue to access the same kind of healthcare available in the general community. Financial or logistical justifications cannot be cited for justifying denial.

For a prisoner with disability, the punishment lies only in the denial of liberty. It should not extend to denial of humane treatment or reasonable accommodation. Many prison manuals wrongly conflate sensory or physical impairments with cognitive decline and mental illness, thereby preventing the grant of reasonable accommodation.

The Tamil Nadu government has its task cut out. The judgement directs it to take measures, including identification of prisoners with disabilities at the time of incarceration, amendment of its prison manual to bring in disability rights-respecting measures, and mandatory sensitisation of prison officials. Tamil Nadu would do well to engage with persons with disabilities, disabled persons’ organisations, and rights groups to implement these directives effectively. While the ruling applies to Tamil Nadu, it can serve as a template for prison reform across India. Every state prison manual needs to be brought in line with the RPwD Act and the Model Prison Manual, 2016. Judicial oversight might be the only channel to overcome institutional inertia.

As the Court observed, the NCRB does not record the number of prisoners with disabilities – a glaring omission that obstructs accountability and reform. This judgement underscores the need to integrate disability data across the criminal justice system. The Court’s directions, if implemented, will help address this problem in Tamil Nadu, but this judgement should spur the NCRB to take corrective steps on this front nationwide.

This landmark decision provides a robust judicial foundation for prison reform through the lens of disability rights. But the real challenge lies in implementation. Reforming prison systems requires political will, budgetary allocation, training of personnel, and sustained civil society engagement. Otherwise, judicial wisdom will remain confined to courtrooms and law reports, far removed from the concrete and bars of our jails.

We must remember: prisoners do not lose their humanity at the threshold of incarceration. The Supreme Court has held the mirror up to the State – now, it is up to governments, disability rights groups, and citizens to respond.