Chains Can’t Bind Rights: Landmark Verdict on Disabled Prisoners’ Care -

In early 2020, advocate L. Muruganantham, diagnosed with Becker muscular dystrophy, autism spectrum disorder, and ARFID, was falsely arrested in Tamil Nadu during a family property dispute and spent approximately ten days in Coimbatore Central Prison (29 February to 10 March 2020). His disability worsened, rising from 70% to 80% in that period. He alleged denial of protein-rich diet, physiotherapy, accessible sanitation, and other accommodations owed under the Rights of Persons with Disabilities Act, 2016 and constitutional guarantees.

He initially approached the State Human Rights Commission (SHRC), which awarded ₹1 lakh compensation and faulted the police officer but exonerated jail authorities, finding no deliberate neglect in care provision. Dissatisfied, Muruganantham challenged the SHRC order before the Madras High Court. In 2022, the High Court enhanced the compensation to ₹5 lakhs (₹4 lakhs from the State and ₹1 lakh from the officer) and ordered sensitisation training for officials. Still aggrieved that prison officials were not held accountable, he filed an appeal before the Supreme Court of India.

Supreme Court Judgment (15 July 2025)

A Bench of Justices J.B. Pardiwala and R. Mahadevan delivered a landmark verdict in Civil Appeal No. 9487 of 2025, blending personal justice with systemic reform on the following grounds.

Compensation and Liability

The Court upheld the ₹5 lakh compensation, recognising that the illegal arrest and denial of reasonable medical and dietary accommodations violated Muruganantham’s rights under Articles 14 and 21 of the Constitution, as well as the Right of Persons With Disabilities Act 2016 (RPwD Act). However, it refused to impose additional personal liability on jail authorities. It found that the prison had provided basic medical care hospital admission, some protein-rich food like eggs and milk, and a bed in the jail hospital. However, there was a lack of targeted physiotherapy, protein-specific nutrition, and psychological counselling. Since there was no evidence of wilful neglect, the existing compensation was found to be adequate.

The Court also clarified that prisoners are not entitled to indulgent or luxurious diets; the State’s duty is to ensure medical and dietary needs are met in accordance with disability and health status.

Systemic Reforms: The Muruganantham Doctrine

Beyond compensation, the Court issued 15 wide-ranging directions to reform how prisons treat disabled inmates. These directives are now being referred to as the Muruganantham Doctrine.

Key reforms include:

Mandatory identification of disabled inmates at entry and documentation of specific needs.
Infrastructure upgrades for accessibility, including ramps, disabled-friendly toilets, and wheelchair-compatible spaces.
Providing rules and procedures in Braille, large print, sign language, and easy-to-read formats.
Access to specialised healthcare, including physiotherapy, psychotherapy, assistive devices, and clinically required nutrition.
Sensitisation and regular training for prison staff and police on disability rights.
Amendments to Prison Manuals to align with the RPwD Act and international human rights norms.
Bi-annual access audits and data collection on prisoners with disabilities.
Compliance reports to be submitted to State Human Rights Commissions within three months.

The Court explicitly stated that prisons must uphold the constitutional and statutory rights of prisoners with disabilities and integrate these into prison administration.

Denial of Basic Prison Care = Violation of Fundamental Rights

The most powerful contribution of this judgment is its unambiguous holding that denial of basic care to disabled prisoners is a violation of their fundamental rights.

Under Article 21, the right to life includes the right to dignity, healthcare, and humane conditions—none of which are suspended during incarceration.
Under Article 14, persons with disabilities must be treated equitably and not subjected to indirect discrimination due to inaccessible environments.
The RPwD Act, 2016 obligates the State to provide reasonable accommodations in all public institutions, including jails.
The judgment drew from international standards such as the UN Convention on the Rights of Persons with Disabilities (UNCRPD) and the Nelson Mandela Rules, which emphasise humane treatment and medical parity for all prisoners.

Importantly, the Court stressed that the denial of medically necessary food, therapy, or aids—even unintentionally can infringe on Articles 14 and 21.

Broader Significance

This judgment marks a major shift in Indian prison jurisprudence:

It embeds the RPwD Act into custodial administration.
It introduces affirmative obligations on jail authorities to ensure accessibility and dignity.
It converts Prison Manuals into living documents, capable of evolving with human rights norms.
The emphasis on audits, data collection, and officer training creates institutional accountability.
The ruling also offers legal ammunition for future PILs challenging inhumane prison conditions across the country.

Conclusion

The Supreme Court in L. Muruganantham v. State of Tamil Nadu has set a new precedent for disability rights in Indian prisons. The judgment affirms that incarceration does not extinguish fundamental rights. It establishes that the State has a continuing obligation to care for disabled prisoners in a manner that upholds their dignity and health.

This verdict is not just a win for one man it is a blueprint for systemic prison reform, setting a high standard for humane treatment, equality, and accessibility for India’s incarcerated disabled population.

“Incarceration may restrict liberty; it must never crush dignity.”

Sources

More Current Affairs: https://learnproacademy.in/updates/