Author(s): Nityashree Bhuvanaprasad and Ashlaisha Divekar
Paper Details: Volume 3, Issue 4
Citation: IJLSSS 3(4) 50
Page No: 669 – 679
The Supreme Court, in its recent judgement penned down in the case of L. Muruganantham v. The State of Tamil Nadu mandated and set guidelines for inclusive prison reforms for the better realisation of rights of prisoners with disabilities within the Indian Criminal Justice System. The Supreme Court in an effort to reconcile India’s persistent efforts towards inclusion and accessibility with the dismal reality of India’s prison infrastructure listed a comprehensive set of guidelines and amendments to be brought forth in the State Prison Manuals to better house disabled prisoners facing incarceration. The present paper attempts to chart the evolution of judicial reasoning in this case, from its institution before the State Human Rights Commission till the recent Supreme Court analysis. Secondly, using a comparative analysis of select Western jurisprudence and practice, it argues for more institutional and legislative changes beyond mere administrative guidelines, to strengthen the endeavour towards better prison treatment for individuals suffering from disabilities, in line with their rights under the RPwD Act and India’s International commitments.
A. INTRODUCTION
In yet another crucial judgement circling disability rights and prison reforms, the Supreme Court, on 15th July 2025, finally addressed the pervasive issues of systemic neglect of disabled prisoners through the judgement pronounced in L. Muruganantham v. State of Tamil Nadu.[1] This judgment, pronounced by the Division bench composed of Justices J.B. Pardiwala and R. Mahadevan marks an end to a case instituted in 2020, and sheds much needed light on the limitations of the current institutional prison system for prisoners suffering from benchmark disabilities. The final judgement is multifaceted, addressing issues and violations in areas ranging from human rights and constitutional safeguards to administrative inefficacy in matters of treatment of disabled prisoners within the criminal justice system.
While India, on a global platform, is committed to the cause of the human rights regime vis-a-vis the rights of disabled people, our prison reforms remain woefully inadequate and resistant to any positive change aligning with the same. According to the latest Prison Statistics India Report,[2] while we have adequate data on caste-based classifications and undertrials within the criminal justice system, there is no statistical data collected that captures useful information regarding prisoners with disabilities. Globally, the disabled population constitutes 16% of the total, making it the largest demographic minority.[3]
Article 31 of The United Nations Convention on the Rights of Persons with Disabilities mandates the collection and publication of data pertaining to persons with disabilities to better implement reforms in multifarious areas to realise the goals of the UNCRPD.[4] Despite being a state party, India has not yet taken active steps to invoke this obligation specifically in the landscape of prison reforms. The PSI Annual Reports still do not contain any statistical information of the population of disabled prisoners within Indian jails. Neither do State prisons publish or maintain records on disabilities of their institutionalised prisoners. Sections 39 and 47 (1) (a) of The Rights of Persons with Disabilities Act, 2016[5] calling for awareness and sensitization programmes, remain woefully unutilised and unimplemented by the administrative authorities who are required to ensure the same.
In light of the same, recent years have seen a surge of instances of rights violations stemming from these administrative lacunae in the Indian Criminal Justice Reforms, the most recent being the present case instituted by Advocate L. Muruganantham. This present paper attempts to analyse the Supreme Court’s judgement on the same, and the guidelines effectively pronounced by the division bench. Additionally, the authors attempt at including further legislative and policy-based solutions, that can be inculcated and adopted to strengthen the case for more effective reforms, aiming at making prisons more inclusive and accessible, rather than debilitating for disabled.
B. Tracing the Facts: Arrest And Detention Of L. Muruganantham
L. Muruganantham, the appellant in the matter, was an advocate who suffered from Becker Muscular Dystrophy, commonly associated with progressive muscular weakness. He also suffered from autism, and Avoidant/ Restrictive Food Intake Disorder (ARFID), a condition recognized under DSM-5. Owing to a frivolous complaint filed by his paternal uncle over a property dispute, the appellant was arrested on 29th February 2020, under Sections 294(b), 323 and 506(ii) of the Indian Penal Code, 1860 and remanded to judicial custody.
Apart from allegations of harassment and torture that the Police Authorities subjected the appellant to, the appellant’s main contentions revolved around the living conditions during his incarceration at the Coimbatore Central Prison, during the course of which, the severity of his disability exacerbated from 70% (as recorded in 2013) to 80%, as tested immediately post his release from prison.[6]
The appellant alleged that the prison authorities failed to provide him with proper food, healthcare, and treatment, as directed under the Rights of Persons with Disabilities Act, 2016 (RPwD Act). Apart from the glaring inadequacies in prison infrastructure, the appellant also argued that there was a debilitating lack of awareness and sensitization amongst the prison staff and police as to the rights of persons suffering from disabilities.
Despite informing the requisite authorities regarding his condition, the appellant was not treated in accordance with his rights under The RPwD Act as well as Articles 14 and 21 of the Indian Constitution, evident from the denial of facilities for psychotherapy, physiotherapy, lack of protein rich diet, lack of infrastructural facilities such as low sensory environments, ramps, disability-friendly sanitation facilities, and warm water for bathing.
As a result of his treatment while incarcerated, the appellant’s health deteriorated, resulting in sleep deprivation, ulceration, chronic pain, and long-term psychological ramifications. His deteriorated health also impacted his eligibility for advanced gene therapy, the treatment for which costed the appellant over Rs. 16 Crores.
C. CHRONOLOGY OF LEGAL PROCEEDINGS
The case of L. Muruganantham v. State of Tamil Nadu[7] represents a significant juncture in the evolving jurisprudence on custodial rights and disability justice in India. The journey behind this watershed judgment began at the State Human Rights Commission (SHRC), where L. Muruganantham was falsely implicated in a criminal case that was orchestrated by his family member for usurping his property. The appellant approached the SHRC by filing a complaint seeking compensation of ₹ 50,00,000 for the mistreatment and the loss of life and liberty he encountered during his imprisonment. The appellant also sought payment of ₹ 2 crores to the Disability Rights Public Fund under the RPwD Act 2016, as compensation for the violation of his fundamental rights.
The SHRC supported the appellant’s claims on wrongful arrest, but they chose to award a modest compensation of only ₹1,00,000, while recommending disciplinary action against the arresting officer. Any claims made by the appellant towards the undignified conditions of living within the prison was dismissed by the commission. However, the commission recommended to the government of Tamil Nadu that active efforts must be taken to make state prisons accessible for persons with disabilities in accordance with the RPwD Act, and in line with the law declared in the case of Rajiv Raturi vs. Union of India.[8] The emphasis on right to life under Article 21[9] including the right to accessibility was emphasised in the judgment. Hence, the Supreme Court mandated that government buildings and public spaces must be completely accessible to persons with disabilities by June 2019.
Challenging this order further, given the incomplete relief, Muruganantham filed a writ in the Madras High Court under W.P.No.22431 of 2021 seeking a writ of Certiorarified Mandamus against the SHRC’s dismissal of the appellant’s complaints against Respondent no.3 and 1, and to seek further compensation for the human rights violations committed against him. The High Court used strong language to criticize the police’s indifference to the Arnesh Kumar v. State of Bihar (2014) guidelines, particularly the duty to avoid routine arrests in minor offences and to apply heightened care when dealing with vulnerable individuals such as persons with disabilities. The High Court noted that the appellant was denied adequate medical care, food, and basic amenities during incarceration, violating his statutory rights. While the appellant claimed this amounted to a human rights violation under Section 2(d) of the Protection of Human Rights Act[10], the RPwD Act, and Articles 14[11] and 21[12] of the Constitution, the SHRC only awarded only ₹1,00,000 as compensation, which the High Court marginally enhanced to ₹5,00,000.
Taking his case to the highest level, Muruganantham appealed to the Supreme Court for increased compensation, with a demand for systemic reforms in the prison complexes of India. He was dissatisfied with the previous compensation, which merely covered the human rights violations exhibited by the police officials and not the worsening of his disability due to inhumane prison conditions. The Court, while refusing to further enhance the monetary award, affirmed the illegality of his arrest and acknowledged the failure of the state machinery in safeguarding his dignity. The Court reasoned that the responsibility to accommodate special needs does not impose an unqualified obligation on the State in every instance. Nonetheless, the judgment drew upon a robust body of precedent to reinforce the normative framework of disability rights. In Vikash Kumar v. UPSC (2021)[13], the Supreme Court had held that the denial of reasonable accommodation under the RPwD Act constitutes a form of discrimination. The Court also referenced Jeeja Ghosh v. Union of India (2016)[14], which underscored the human rights-based approach to disability, and Rajiv Raturi v. Union of India (2017)[15], which established the obligation to ensure accessible public infrastructure as intrinsic to the right to life and dignity under Article 21.
The Court also took note of Re: Inhuman Conditions in 1382 Prisons (2016)[16] and Shri Rama Murthy v. State of Karnataka (1997)[17], highlighting systemic neglect in Indian prisons. It emphasized that lawful incarceration does not suspend the right to dignity and reaffirmed the applicability of international standards such as the UNCRPD and the Nelson Mandela Rules.
D. EVALUATING THE SUPREME COURT’S INTERPRETATION
The Supreme Court’s judgment in L. Muruganantham v. State of Tamil Nadu reflects an evolving judicial approach to the intersection of disability rights and custodial safeguards, as it scrutinises the treatment of a disabled detainee within the framework of constitutional protections and statutory mandates. While the Court acknowledged that the appellant was subjected to an arbitrary arrest and a frivolous FIR, the undisputed fact remained that he had endured incarceration from 29.02.2020 to10.03.2020, a period during which his physical condition deteriorated further.
The Court had two primary issues before it for consideration: whether the High Court’s enhancement of compensation to ₹5,00,000 from ₹1,00,000 for the appellant was adequate or further relief was warranted; and whether prisoners with disabilities in Tamil Nadu’s prisons are being provided adequate facilities in compliance with the Rights of Persons with Disabilities Act, 2016 and relevant international conventions.
The Supreme Court held that the arrest of the appellant was illegal and constituted an abuse of power by Respondent No. 2, violating the procedural safeguards against arbitrary arrest as established in Arnesh Kumar v. State of Bihar (2014)[18]. The judgment in Arnesh Kumar highlights the necessity of avoiding unwarranted arrests, particularly in cases involving persons with disabilities, where the law demands the highest degree of prudence and sensitivity from police authorities. The failure of the officers to take into account the appellant’s disability not only disregarded these safeguards but also aggravated the illegality of the arrest, further endangering the condition of an already vulnerable individual.
The Court further analysed the appellant’s treatment while in custody, wherein the appellant had alleged that the prison authorities failed in providing him with appropriate medical care, dietary accommodations, and psychological support, all of which led to a deterioration in his physical and mental health. The denial of these amenities to the appellant constitutes a blatant violation of S.3(5), S.6, S.25 and S.40 of the RPwD Act[19]. The respondents, however, argued that the appellant had been housed in the prison hospital for the entirety of his incarceration and had been provided with special amenities, including dietary supplements and medical supervision, under his disability. The Court acknowledged that the appellant had not been provided with certain essential items such as protein-rich foods and intensive physiotherapy. Nonetheless, the Court observed that he had remained in the prison hospital throughout his incarceration and had been given some level of accommodation for his condition.
The Court’s approach tried to strike a balance between meeting the needs of persons with disability but reiterating that prisons are correctional institutions and are not supposed to be a place of comfort. Taking the example of G.N. Saibaba[20], a man bound to a wheelchair because of polio, who was 90% disabled, spent a decade behind bars under the Unlawful Activities Prevention Act, suffered several health complications due to the corrosive environment he was exposed to in the prison, which ultimately led to his demise. Several such cases, even that of Stan Swamy[21], diagnosed with Parkinson’s disease, only prove that the prison complex in India enforces and sustains disability, as the very idea of accommodating special needs is antithetical to the ideas of carceral punishment. Carceral institutions propagate ableist ideals under the cloak of justice because the foundations upon which they are built view disability and criminality through a similar lens. In this line of thought, the Court found it appropriate for the appellant to be granted ₹4,00,000 from the state, and ₹1,00,000 from the concerned police officer, along with an additional ₹25,000 towards the costs payable to the appellant, as ordered by the High Court. The Court tried to opine that while the appellant deserved to have adequate medical and nutritional support that is required for his condition, the denial of the same cannot be attributed to human rights violations under Article 21 of the Constitution. The right to life under Article 21 includes the right to dignity and health, but this must be interpreted in the context of prison administration, where the standard is one of adequacy, not preference.
The most important divergence that the Apex court takes from the High court’s order is on how panoramic its view is towards the larger issue of how disabled prisoners are accommodated within India’s prison system. By choosing its focus towards rehabilitation and reintegration of prisoners with disabilities into society, the Court, in its order, proposed a series of reforms that remodel how prisons in Tamil Nadu should function and provide appropriate accommodation to vulnerable persons to ensure a humane and just carceral system, and uphold the standards of equality and dignity enshrined within our constitution.
First, the Court directed the State to conduct a comprehensive accessibility audit of all prisons within six months, in line with the Harmonised Guidelines and Standards for Universal Accessibility in India 2021. This audit is intended to identify structural and operational gaps affecting disabled inmates. Following the audit, the State is obligated to ensure full accessibility of prison infrastructure as mandated under Sections 40[22] and 45[23] of the Rights of Persons with Disabilities Act, 2016 and Rule 15[24] of the corresponding Rules. This includes the installation of ramps, disabled-friendly toilets, and the provision of assistive devices and necessary spatial modifications. The Court also mandated that prison authorities provide individualised medical care such as physiotherapy, psychiatric treatment, and speech therapy, alongside nutrition tailored to each inmate’s medical needs, as recommended by certified medical professionals. The Court also directed that regular sensitisation programmes be conducted for prison officials and medical personnel, ideally in partnership with disability rights organisations or academic institutions.
Further, the State Government was instructed to amend the Tamil Nadu Prison Rules, 1983[25], to align with the RPwD Act, the UN Convention on the Rights of Persons with Disabilities (UNCRPD)[26], and the Model Prison Manual, 2016[27]. These amendments must explicitly provide for reasonable accommodation, access to assistive technologies, and proper grievance redressal mechanisms. In terms of transparency and accountability, the State was directed to maintain disaggregated data on prisoners with disabilities, including the nature of their impairments and the accommodations provided. This information is to be regularly updated and made publicly available through the official website of the Tamil Nadu Prisons Department, in line with Article 31 of the UNCRPD. Lastly, the Court entrusted the Tamil Nadu State Legal Services Authority (SLSA) with monitoring the implementation of these directions, including the conduct of targeted prison visits, facilitation of legal aid, and submission of annual compliance reports to the Madras High Court. Through these comprehensive directives, the Court signalled a shift from case-specific adjudication to structural reform grounded in constitutional mandates and international human rights obligations.
E. CRITICAL LENS ON DISABILITY, DIGNITY, AND DUE PROCESS
Any administrative delegation by the judiciary will inevitably face a roadblock in the absence of legislative policies outlining a larger rights-based structure. This is especially true in the case of prison governance, which falls under Entry 4 List II of the Seventh Schedule, i.e. the State List.[28] States are bound, to inculcate in their Prison Manuals, directives as under section 5(3) of The Model Prisons and Correctional Services Act, 2023, which allow prisons to be segregated based on the specific housing needs of disabled prisoners, both physically disabled, and those suffering from mental illnesses.[29]
Despite the same, State Prison Manuals remain obsolete and reliant on the same conventional infrastructure responsible for exacerbating the conditions of disabled prisoners. The Model Prisons Act, as well as the Model Prisons Manual, 2016[30] in its chapters XXIV and XXV provides extensive details on how to house incarcerated female, transgender, and young offenders,[31] but provides no guidance on how to address the needs of the disabled population in prisons. Firstly, annual PSI reports must mandatorily be directed to include data on disabilities and capacities of prisons to house disabled prisoners.
What is also required, is an overseeing administrative authority which has the statutory power to mandate and oversee infrastructural developments in individual prisons. Reference can be drawn to UK’s practice of handing prison handbooks to prisoners, which details their rights and resources available, and is handed out to every prisoner.[32] Additionally, administrative officers such as Prison Ombudsman and Disability Liaison Officers must also be instituted in the context of state and local Indian prisons, to whom aggrieved prisoners can take their complaints; who can address the same and ensure that the prison infrastructure is up to date. Amendments must be introduced in the RPwD Act or the Prison Reforms Act, mandating the setup of local Disability Boards or Officers in each prison to ensure that prisoners are not harassed or tortured by personnel and prison staff.
F. CONCLUSION
The Supreme Court’s ratio is undoubtedly a welcome step towards equitable accommodation and treatment of prisoners in the Indian Criminal Justice System. However, India needs to fall more in step with international best practices, as elucidated above. It is universal, that incarceration, while part of India’s reformative approach towards penalization, disproportionately, and negatively affects those with disabilities. There is an urgent need for India to reevaluate its carceral system, which currently prioritizes incapacitation over reform. A shift toward a more reformative approach is essential to enable the rehabilitation and reintegration of prisoners into society. This gap between ground reality and human rights goal must be reconciled by adopting a humanitarian and humanistic approach towards prison reform. Indian administration must ensure that the necessary changes are made so that persons with disabilities are provided with equitable treatment in prisons. Incarcerated prisoners cannot be treated as secondary objects and cannot be deprived of what is their basic human right to reasonable accommodation and living conditions in light of their physical or mental condition.
[1] 2025 INSC 844
[2] Supreme Court of India, Report on Prisons in India (2024) https://cdnbbsr.s3waas.gov.in/s3ec0490f1f4972d133619a60c30f3559e/uploads/2024/11/2024110677.pdf.
[3] World Health Organization. Global report on health equity for persons with disabilities. World Health Organization; 2022 Dec 2 [Cited 2025 July 20]. Available from: https://www.who.int/teams/noncommunicable-diseases/sensory-functions-disability-and-rehabilitation/global-report-on-health-equity-for-persons-with-disabilities
[4] United Nations Convention on The Rights of Persons with Disabilities, art. XXXI, A/RES/61/106
[5] The Rights of Persons with Disabilities Act, 2016, § 39, 47(1)(a) (India).
[6] Supra note 1,¶ 3.
[7] L. Muruganantham v. State of Tamil Nadu & Others (2025 INSC 844)
[8] Rajiv Raturi vs. Union of India 2024 INSC 858.
[9] INDIA CONST. art. 21.
[10] Protection of Human Rights Act, 1994, § 2 (d) (India).
[11] INDIA CONST. art. 14.
[12] Supra, note 9.
[13] Vikash Kumar vs Union Public Service Commission, AIRONLINE 2021 SC 56
[14] Jeeja Ghosh v. Union of India, AIR 2016 SUPREME COURT 2393
[15] Supra, note 4.
[16] In Re: Inhuman Conditions in 1382 Prisons, 2016 INSC 144
[17] Shri Rama Murthy v. State of Karnataka (1997), AIR 1997 SUPREME COURT 1739
[18] Arnesh Kumar v. State of Bihar, AIR 2014 SUPREME COURT 2756
[19] The Rights of Persons with Disabilities Act, 2016 (India).
[20] Pariplab Chakraborty, How Prisons Perpetuate and Produce Disabilities, The Wire, (Oct 23, 2024), https://thewire.in/health/gn-saibaba-prisons-perpetuate-produce-disabilities
[21] Ibid.
[22] The Rights of Persons with Disabilities Act, 2016, § 40 (India).
[23] The Rights of Persons with Disabilities Act, 2016, § 45 (India).
[24] The Rights of Persons with Disabilities Rules, 2017, Rule 15 (India)
[25] Tamil Nadu Prison Rules, 1983
[26] Supra, at note 4.
[27] Model Prisons Manual, 2016, Gazette of India.
[28] India Const., Enty 4 List II Sch. VII.
[29] The Model Prisons and Correctional Services Act, 2023, § 5(3).
[30] Supra note 27.
[31] Ibid.
[32] Srishti Gaur, Hanging between Justice and Dignity: Advocating for Disability-Inclusive Prison Reforms- Part II (December 31, 2024) https://lawandotherthings.com/hanging-between-justice-and-dignity-advocating-for-disability-inclusive-prison-reforms-part-ii/.