LexL. MURUGANANTHAM versus STATE OF TAMIL NADU & OTHERS
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[2025] 7 S.C.R. 935 : 2025 INSC 844 L. Muruganantham v. State of Tamil Nadu & Others (Civil Appeal No. 9487 of 2025) 15 July 2025 [J.B. Pardiwala and R. Mahadevan,* JJ.] Issue for Consideration (A) Whether the order of the High Court enhancing compensation to Rs.5,00,000/- for the alleged violations committed against the appellant, while dismissing the complaint against respondent no.3, and partly allowing the complaint against respondent no.2, calls for interference by this Court; and (B) Whether adequate and appropriate facilities are being made available to prisoners with disabilities during incarceration in the prisons of Tamil Nadu, in compliance with the provisions of the RPwD Act, 2016 and UNCPRD. Headnotes† Constitution of India – Arts.14 and 21 – Rights of Persons with Disabilities Act, 2016 – United Nations Convention on the Rights of Persons with Disabilities, 2006 – Prisoners with disabilities – Appellant herein suffers from Becker Muscular Dystrophy, Autism Spectrum Disorder, and associated psychological conditions – An FIR was filed against him – Appellant was arrested – According to the appellant, during his incarceration, the prison authorities failed to provide him with appropriate food, medical care, and other necessary support considering his physical disability, which led to a deterioration in his health – Consequently, he lodged a complaint before the SHRC – The SHRC awarded Rs.1,00,000/- as compensation and directed initiation of disciplinary proceedings against erring police officer-respondent no.2 – The High Court enhanced the compensation to Rs.5,00,000/- and awarded costs of Rs.25,000/- to the appellant – The direction for disciplinary action against respondent no.2, was affirmed by the High Court and complaint against respondent no.3 (the prison authorities) was dismissed – Whether the order passed by the High Court require interference: * Author 936 [2025] 7 S.C.R. Supreme Court Reports Held: 1. The deficiencies in prison facilities may not be directly attributable to the respondent authorities in the present case – Accordingly, they cannot be held liable for the same – The direction issued by the High Court for initiation of departmental proceedings against respondent no.2, as well as the dismissal of the complaint against respondent no.3 (the prison authorities), appears to be well-reasoned and based on a careful appreciation of the facts and evidence on record – In contrast, no material was produced by the appellant to establish wilful negligence or deliberate omission on the part of the prison authorities to warrant a finding of human rights violation – There is no justification to disturb conclusions reached by the High Court. [Para 22] 2. While it is evident that the appellant did not receive certain medical and dietary facilities appropriate to his condition during incarceration, the records indicate that he remained in the prison hospital throughout and was provided with some special amenities recognising his disability – The absence of specific provisions, such as protein-rich food or specialised medical interventions appears to stem from institutional limitations within the prison system rather than from any deliberate neglect or malice on the part of the prison authorities – Mere non-supply of preferred or costly food items cannot ipso facto be treated as a violation of fundamental rights – Prisons are correctional institutions–not extensions of civil society’s comforts – The non-supply of non-essential or indulgent items does not amount to a constitutional or human rights violation unless it results in demonstrable harm to health or dignity – Considering the nature of the appellant’s disability (assessed at 80%), the progressive deterioration of his health during custody, the High Court was justified in enhancing the compensation from Rs.1,00,000/- to Rs.5,00,000/-. [Paras 21.1, 21.2, 21.3] Prison Reforms – Urgent need – Improvement of quality of life of inmates – Discussed. Rights of Prisoners with disabilities – Obligation of the State: Held: The State has a constitutional and moral obligation to uphold the rights of prisoners with disabilities – This includes not only ensuring non-discriminatory treatment but also enabling their effective rehabilitation and reintegration into society – This Court emphasizes that reasonable accommodations are not optional, but integral to any humane and just carceral system – A sy
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