Supreme Court Issues Landmark Guidelines on Rights of Prisoners with Disabilities, calls it "The Muruganantham Doctrine"

Court: The Supreme Court of India
Bench: Justice J.B. Pardiwala and Justice R. Mahadevan
Case Title: L. Muruganantham v. State of Tamil Nadu & Others
Citation: 2025 INSC 844
Date of Judgment: July 15, 2025 

Precedents Cited

• Arnesh Kumar v. State of Bihar (2014) 8 SCC 273 – Arrest guidelines violated; factual foundation for compensation.
• Vikash Kumar v. UPSC (2021) 12 SCR 311 – Recognised denial of reasonable accommodation as discrimination under Art. 14/21; Court extends principle to prisons.
• Jeeja Ghosh v. Union of India (2016) 4 SCR 638 – Human-rights-based approach to disability; influences Court’s interpretive stance.
• Re: Inhuman Conditions in 1382 Prisons (2017) 10 SCC 658 – Framework of prison reforms adopted and expanded.
• Rama Murthy v. State Of Karnataka (1997) 2 SCC 642 – Need for an All-India Jail Manual and recognition of prisoners’ double handicap (ill-health and incarceration).
• People’s Watch v. Home Secretary, TN (2023) 2 MLJ 478 – Emphasised visitorial oversight; its directives were “re-emphasised”.
• International Instruments: UN Convention on the Rights of Persons with Disabilities (UNCRPD); UN Standard Minimum Rules for the Treatment of Prisoners (Nelson Mandela Rules).

Overview:

This case highlights the critical need for systemic reforms in Indian prisons to ensure the rights and dignity of prisoners with disabilities. The appellant, L. Muruganantham, a physically challenged advocate with Becker Muscular Dystrophy, autism, and mental illness, was illegally arrested and incarcerated. He alleged that during his custody, he was denied proper food, medical treatment, and accessible facilities, leading to a deterioration of his health.

Issues Before the Court

1. What constitutes “reasonable accommodation” for prisoners with disabilities under the Rights of Persons with Disabilities Act, 2016 (RPwD Act)?
2. Do infrastructural or administrative shortcomings in prisons amount to human rights violations requiring compensation?
3. What structural reforms are constitutionally necessary to safeguard dignity and equality of prisoners with disabilities?

Factual Background and Journey Through Courts:

• Illegal Arrest and Harassment: The appellant was falsely implicated in a criminal case and illegally arrested by Respondent No. 2 (police officer) at the behest of his paternal uncle.
• Incarceration and Alleged Neglect: During his incarceration from February 29, 2020, to March 10, 2020, at Central Prison, Coimbatore, the appellant alleged denial of essential support, including physiotherapy, psychotherapy, protein-rich food, and accessible sanitation facilities. He claimed this aggravated his physical and mental health conditions.
• SHRC Proceedings: The appellant filed a complaint with the SHRC, seeking compensation and action against officials. The SHRC awarded Rs. 1,00,000/- compensation and recommended disciplinary action against Respondent No. 2, but dismissed the complaint against the prison authorities (Respondent No. 3), finding no specific human rights violation attributable to them.
• High Court Proceedings: Aggrieved by the SHRC's limited relief, the appellant filed a writ petition. The High Court partly allowed his petition, enhancing the compensation to Rs. 5,00,000/- (Rs. 4,00,000/- from the State and Rs. 1,00,000/- recoverable from Respondent No. 2) and awarding Rs. 25,000/- in costs. However, it upheld the dismissal of the complaint against the prison authorities, stating that while the arrest was a human rights violation, the non-provision of certain amenities during a short incarceration period did not amount to a "serious Human Rights violation" by jail authorities.
• Supreme Court's Findings:
  • The Supreme Court affirmed the findings of illegal arrest and harassment.
  • It found the enhanced compensation of Rs. 5,00,000/- to be "fair, just, and reasonable," noting that while the appellant did not receive certain appropriate medical and dietary facilities, this stemmed from "institutional limitations" rather than "deliberate neglect or malice" by prison authorities. Thus, these shortcomings did not, "per se, amount to a violation of human rights attributable to the jail authorities."
  • However, the Court expressed "deep concern" over the systemic neglect of incarcerated individuals with disabilities and emphasized the urgent need for comprehensive prison reforms.

Key Takeaways 

This Supreme Court judgment, while affirming existing compensation, serves as a landmark directive for advancing disability rights within the Indian carceral system. Here are the key takeaways for our blog:

1. Reinforcing the Right to Dignity and Accessibility in Prisons: The Court unequivocally states that "Lawful incarceration does not suspend the right to human dignity." It stresses that failure to provide reasonable accommodations and basic care to disabled prisoners is not merely an administrative lapse but a violation of fundamental rights under Articles 14 and 21 of the Constitution, and breaches the RPwD Act, 2016, and UNCRPD.
2. Beyond "Deliberate Neglect": Systemic Failure as a Violation: While the Court didn't attribute "human rights violation" to prison authorities in this specific instance due to lack of "deliberate neglect," it highlighted "institutional limitations" as the root cause. This implicitly recognizes that systemic failures leading to deprivation of rights for disabled prisoners are unacceptable and necessitate immediate attention.
3. Mandatory Healthcare and Assistive Devices: The judgment reiterates that persons with disabilities in custody must receive healthcare "equivalent to that available in the general community," including physiotherapy, speech therapy, psychiatric care, and assistive devices. This is a crucial affirmation of their right to comprehensive medical support, explicitly stating that "Logistical or financial limitations cannot be cited to justify a withdrawal of this obligation."
4. Comprehensive Directives for Prison Reforms: The Supreme Court has issued 15 comprehensive, "immediate and time-bound" directives covering:
   • Identification and Information: Prompt identification of disabled prisoners and provision of information in accessible formats.
   • Infrastructure Accessibility: Mandating wheelchair-friendly spaces, accessible toilets, ramps, and sensory-safe environments.
   • Therapeutic Services: Dedicated spaces for physiotherapy, psychotherapy, and other therapeutic services.
   • Audits and Compliance: State-level access audits and compliance with accessibility guidelines (Harmonized Guidelines and Standards for Universal Accessibility in India – 2021).
   • Training and Sensitization: Comprehensive training for all prison staff and medical officers on disability rights, appropriate handling, and non-discrimination.
   • Dietary Needs: Provision of nutritious and medically appropriate diets tailored to individual needs.
   • Manual Review and Amendment: Review and amendment of the State Prison Manual to conform with the RPwD Act and UNCRPD, prohibiting discrimination and promoting reasonable accommodation.
   • Data Collection and Transparency: Maintenance and public dissemination of disaggregated data on disability status, accessibility, and accommodations (compliance with Article 31 UNCRPD).
   • Consultation and Monitoring: Periodic consultations with civil society organizations and constitution of monitoring committees.
5. Emphasis on International Standards: The judgment frequently references the UNCRPD and the United Nations Standard Minimum Rules for the Treatment of Prisoners (Nelson Mandela Rules), reinforcing India's commitment to international human rights standards for incarcerated persons with disabilities.
6. Accountability and Public Interest: The Court emphasizes that these directions are "in the larger public interest to uphold the dignity, and healthcare rights of prisoners with disabilities in all custodial settings," underscoring the State's "constitutional and moral obligation." The requirement for compliance reports to the State Human Rights Commission every three months ensures a mechanism for accountability.

This judgment provides a strong judicial push for a "systemic transformation" towards a "humane and just carceral system" that affirms the rights and provides necessary care for the rehabilitation of prisoners with disabilities. It sets a clear roadmap for state governments to implement the RPwD Act and international obligations effectively within their prison systems.

Read the judgement in L. Muruganantham v. State of Tamil Nadu & Others embedded below: