Compensation Can’t Cure Systemic Neglect: Supreme Court Directs Comprehensive Reforms, but Refuses Higher Compensation in Disabled Lawyer’s Custodial Torture Case

“Right to Dignity in Prisons Extends to Disabled Inmates”, the Supreme Court of India, in a pathbreaking ruling delivered a landmark judgment addressing the long-neglected rights of prisoners with disabilities. The Bench of Justice J.B. Pardiwala and Justice R. Mahadevan upheld a compensation award of ₹5,00,000/- to a disabled advocate illegally arrested and tortured in custody but, more significantly, issued unprecedented systemic directions to overhaul prison conditions across Tamil Nadu to align with constitutional, statutory, and international human rights standards.

The Court, while affirming the compensation order of the Madras High Court, made it abundantly clear:

“While monetary compensation mitigates individual suffering, systemic discrimination must be addressed through transformative reforms. A civilised society cannot sanction a carceral regime that reduces persons with disabilities to a life of indignity and deprivation.”

This case involved the wrongful arrest and custodial torture of Advocate L. Muruganantham, a person suffering from 80% locomotor disability (Becker’s Muscular Dystrophy), autism spectrum disorder, and mental illness. Arrested due to a vindictive property dispute, he was incarcerated in deplorable conditions, denied essential medical care, therapy, and reasonable accommodations in violation of fundamental rights under Articles 14 and 21 of the Constitution, the Rights of Persons with Disabilities Act, 2016, and the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD).

The Supreme Court pulled up the Tamil Nadu Police for the illegal arrest stating:

“The arrest was in clear breach of the guidelines laid down in Arnesh Kumar v. State of Bihar and represents a shocking abdication of the State’s constitutional obligation to protect the rights of its disabled citizens.”

However, the Court drew a distinction regarding the prison authorities. Acknowledging institutional deficiencies but absence of direct mala fide, it held:

“Deficiencies in infrastructure cannot be conflated with deliberate human rights violations by individual officers. Yet, these gaps are a systemic failure of the State to discharge its constitutional responsibilities.”

In a historic move, the Court directed Tamil Nadu to undertake far-reaching structural reforms:

• Mandatory disability identification at prison admission and maintenance of disaggregated disability data.

• Wheelchair-friendly premises, accessible toilets, sensory-safe environments, and dedicated physiotherapy and psychotherapy units in all prisons.

• Special nutritious diets, appropriate medical care, and assistive devices to be provided mandatorily.

• Annual access audits and periodic monitoring, with compliance reports filed before the State Human Rights Commission.

• Amendments to the outdated Tamil Nadu Prison Rules, 1983, to align with the Rights of Persons with Disabilities Act, 2016, and the Nelson Mandela Rules.

• Mandatory disability sensitisation training for police, prison staff, and medical officers.

• Yearly conferences to monitor progress, supervised by the State Human Rights Commission.

Crucially, the Court reiterated:

“Punishment lies only in deprivation of liberty—not in denial of dignity or healthcare. The prison environment must enable rehabilitation, not worsen suffering, especially for disabled inmates.”

The Court’s refusal to further enhance the ₹5 lakh compensation was premised on the lack of direct mala fide by prison officials and the fact that some accommodations were provided. It clarified:

“Prisons are not extensions of civil society’s comforts. The standard of care must be equitable, adequate, and humane—but not luxurious or indulgent.”

In a sobering reminder to all States, the judgment emphasized:

“The rights of persons with disabilities follow them behind bars. Any failure to provide reasonable accommodations is a form of discrimination prohibited under domestic law and international conventions.”

This ruling is poised to catalyse overdue reforms, compelling State accountability, and redefining the carceral experience for disabled prisoners from neglect to dignity.

Date of Decision: 15th July 2025