Disability rights: Behind bars, but not barred

Source: The post  ‘Disability rights: Behind bars, but not barred’’ has been created, based on “Disability rights: Behind bars, but not barred” published in “NewIndian Express” on 20th December 2025.

UPSC Syllabus: GS Paper-2-Governance

Context: Persons with disabilities constitute one of the most vulnerable groups within the criminal justice system, particularly in Indian prisons where pre-trial incarceration is widespread. In 2025, the Supreme Court delivered two landmark judgements such as L. Muruganantham v. State of Tamil Nadu and Sathyan Naravoor v. Union of India which significantly expanded the rights of disabled prisoners. These judgements reinforce constitutional morality and bridge the gap between disability law and prison administration.

Background and Context

1. The Rights of Persons with Disabilities (RPwD) Act, 2016 was enacted to ensure dignity, equality, and accessibility for persons with disabilities, but its application within prisons remained largely neglected.
2. Disabled prisoners often face denial of basic necessities such as medical care, assistive devices, accessible infrastructure, and personal assistance.
3. The Supreme Court intervened through social action litigation to address this systemic exclusion.

Key Features of the Muruganantham Judgement (2025)

1. The Court directed the identification of disabled prisoners and assessment of their special needs.
2. It mandated provision of medical care, physiotherapy, psychotherapy, and personal assistance.
3. The judgement ordered revision of Prison Manuals in line with the RPwD Act.
4. It required training of prison officials on disability rights and sensitisation.
5. It provided for periodic audits, monitoring committees, and inspections to ensure compliance.
6. Initially, these directives were applicable only to Tamil Nadu.

Expansion through the Sathyan Naravoor Judgement (2025)

1. The Supreme Court extended Muruganantham directives to all States and Union Territories.
2. It directed the establishment of an effective grievance redressal mechanism for disabled prisoners.
3. The Court mandated inclusive education and rehabilitation measures within prisons.
4. It provided for enhanced visitation rights to enable families to assist disabled inmates.
5. Crucially, the Court held that Section 89 of the RPwD Act applies to prison authorities, making violations punishable and ensuring accountability.

Constitutional and Jurisprudential Significance

1. The judgements reaffirm that fundamental rights do not end at prison gates, as held in Sunil Batra.
2. They uphold Articles 14, 19, and 21, ensuring equality, dignity, and humane treatment.
3. The rulings demonstrate constitutional morality, judicial sensitivity, and correction of legislative silence.
4. They strengthen the tradition of social action litigation as an instrument of social justice.

Challenges

1. Poor implementation of prison reforms due to administrative apathy and lack of accountability.
2. Inadequate infrastructure and financial constraints in most prisons.
3. Low awareness and sensitisation of prison officials regarding disability rights.
4. Absence of uniform standards across States and Union Territories.

Way Forward

1. Ensure time-bound implementation of Supreme Court directives through clear SOPs.
2. Conduct mandatory disability audits in all prisons.
3. Revise Prison Manuals in line with the RPwD Act, 2016.
4. Provide adequate budgetary allocations for accessibility and healthcare.
5. Institutionalise training and sensitisation of prison staff.
6. Establish independent monitoring and grievance redress mechanisms.
7. Prefer alternatives to incarceration for severely disabled undertrials.

Conclusion: The Muruganantham and Sathyan Naravoor judgements mark a transformative step in recognising the rights of disabled prisoners. By aligning prison administration with disability law and constitutional values, the Supreme Court has advanced substantive justice. The real test now lies in faithful enforcement to ensure that incarceration does not result in double punishment for disability.

Question: Discuss the significance of recent Supreme Court judgements extending disability rights to prisoners in India. How do these judgements reflect constitutional morality and address systemic deficiencies in prison administration?