Supreme Court Issues Directives on Prison Overcrowding and Human Rights Violations

The Supreme Court of India, in the case of In Re: Inhuman Conditions in 1382 Prisons, delivered a critical judgment addressing the long-standing issue of overcrowding, lack of facilities, and human rights violations in Indian prisons. This case, filed as a writ petition under Article 32 of the Constitution, led to a series of directives aimed at improving prison conditions across multiple states.

Background of the Case

The case originated as a public interest litigation (PIL) highlighting the deteriorating conditions in Indian prisons. The petitioner pointed out that overcrowding, lack of basic sanitation, poor medical facilities, and failure to protect prisoners’ fundamental rights had reached alarming levels. The Supreme Court took cognizance of the matter and sought detailed reports from various states on the status of their jails.

The latest hearing, held on May 14, 2024, reviewed reports from states such as Bihar, Punjab, Chhattisgarh, Rajasthan, Jharkhand, Odisha, and Kerala, among others. The Court found that many states had failed to take adequate steps to address prison conditions despite multiple directives.

Key Legal Issues Considered

Whether the states had complied with earlier Supreme Court orders on improving prison conditions.
Whether the lack of basic facilities, including sanitation, healthcare, and infrastructure, violated Article 21 of the Constitution.
Whether the delays in approval for prison expansion projects amounted to administrative negligence.
What immediate and long-term steps should be taken to address overcrowding and human rights violations?

Arguments by the Amicus Curiae

The Court-appointed Amicus Curiae, Mr. Gaurav Agrawal, presented a detailed report highlighting the deficiencies in state prison systems. The key submissions included:

Many prisons were housing inmates at more than twice their sanctioned capacity.
Several states had not sanctioned funds for prison expansion despite having identified the need for additional space.
Women prisoners lacked basic hygiene facilities, and children living with incarcerated mothers were not receiving adequate care.
Medical facilities in prisons were inadequate, with a shortage of doctors, medicines, and emergency care.
Prison infrastructure, including toilets, kitchens, and barracks, was in a dilapidated state in many states.

State-Wise Observations and Court Directives

Bihar

Jails in Aurangabad, Darbhanga, Gopalganj, and several other districts were operating at double their capacity.
The state had failed to approve expansion plans despite recognizing the need.
The Court directed Bihar to sanction funds within three months and complete identified construction projects by March 2025.

Punjab

The state had proposed a four-phase expansion plan spanning two decades (2024-2044).
The Court found this timeline unacceptable and directed Punjab to fast-track construction and approve necessary projects within three months.

Chhattisgarh

Existing jails were overcrowded, and new barracks were under construction.
The Court directed that ongoing projects be completed by December 2025 and that the state approve additional expansion plans within the next financial year.

Rajasthan

Ongoing prison construction was progressing, but the Court emphasized that timelines must be strictly followed.
The state was directed to submit a quarterly progress report to ensure accountability.

Jharkhand

The Court criticized the state for leaving prison infrastructure decisions to junior officers instead of the Chief Secretary.
The state was directed to approve construction of new jails, including one in Deogarh, and ensure timely implementation of all recommendations.

Odisha

The state had only submitted reports from 13 districts despite having 30 districts.
The Court directed that all remaining districts submit reports and that ongoing expansion plans be expedited.

Kerala

Overcrowding was identified in 13 prisons, but no concrete follow-up actions had been taken.
The state was directed to prioritize urgent prison upgrades and provide a detailed compliance report.

Final Ruling and Directions

The Supreme Court issued the following directives:

All states must approve pending prison expansion plans within three months.
Medical and hygiene facilities must be upgraded, particularly in women’s prisons.
Prison infrastructure, including kitchens, drainage systems, and barracks, must be improved within a strict timeline.
All states must submit compliance reports before the next hearing on July 11, 2024.

The Court emphasized that prisoners retain their fundamental rights under Article 21 and quoted its past rulings in Sunil Batra v. Delhi Administration and Rama Murthy v. State of Karnataka to highlight that prisoners cannot be subjected to inhumane conditions.

Implications of the Judgment

Strengthening Prisoner Rights: The ruling reinforces that prisoners are entitled to basic human rights, including sanitation, healthcare, and dignified living conditions.
State Accountability: The directives ensure that state governments cannot delay prison reforms indefinitely.
Judicial Oversight: By setting a strict timeline and requiring compliance reports, the Supreme Court has taken an active role in monitoring prison conditions.

Conclusion

The Supreme Court’s ruling in this case sets a precedent for prioritizing prison reforms in India. By holding states accountable and setting clear deadlines, the Court has taken a strong stance on ensuring that prisoners are treated with dignity. The upcoming hearing in July 2024 will serve as a crucial checkpoint to assess compliance and further address ongoing issues in the prison system.

Petitioner Name: In Re: Inhuman Conditions in 1382 Prisons.
Respondent Name: Government of India & State Governments.
Judgment By: Justice Hima Kohli, Justice Ahsanuddin Amanullah.
Place Of Incident: India (Multiple States).
Judgment Date: 14-05-2024.

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