Authored By: Samiksha Sharma
Dr. B. R. Ambedkar National Law University, Sonepat
CASE TITLE & CITATION: L. Muruganantham v. State of Tamil Nadu & Others (2025) 10 SCC 401
COURT: Supreme Court of India
BENCH: Justice J.B. Pardiwala and Justice R. Mahadevan
BENCH TYPE: Division Bench
DATE OF JUDGMENT: 15 July 2025
PARTIES INVOLVED
APPELLANT: L. Muruganantham is a lawyer with significant disabilities. These include Becker Muscular Dystrophy, autism spectrum disorder, and related mental health issues. He was held as an undertrial prisoner in Central Prison, Coimbatore, Tamil Nadu.
RESPONDENTS: The State of Tamil Nadu and other prison and State authorities responsible for prison administration, medical care, and inmate welfare.
FACTS OF THE CASE
Muruganantham, the appellant, suffers from Becker Muscular Dystrophy, a progressive neuromuscular disorder that causes severe muscle weakness and limits mobility. He needs constant medical care, physiotherapy, assistive devices like wheelchairs, appropriate dietary support, and an accessible living environment due to his disability.
The appellant claimed that the prison authorities did not provide the necessary facilities for his disability while he was an undertrial prisoner in a central prison in Tamil Nadu. He argued that the prison facilities lacked proper infrastructure for accessibility, especially regarding toilets, living areas, and movement within the prison. He stated that the lack of accessibility made it very hard for him to perform basic daily activities.
The appellant also claimed that he was denied assistive equipment, such as a wheelchair, and that he did not receive regular physiotherapy to help manage his condition. He further alleged that he did not receive the specialized medical care needed to prevent further deterioration of his health. Additionally, his dietary needs, which were medically necessary for his condition, were reportedly ignored.
He claimed that prison staff were not adequately trained to assist people with disabilities. According to him, the prison authorities did not take enough action to address his concerns or those raised by his family, despite repeated attempts to communicate them.
As a result of these conditions, the appellant alleged a decline in his physical health during imprisonment, leading to pain, psychological trauma, and loss of dignity. Upset by the treatment he received, the appellant filed a complaint with the State Human Rights Commission (SHRC), Tamil Nadu, arguing that his fundamental and statutory rights as a person with a disability were violated under Article 21 of the Constitution of India and the Rights of Persons with Disabilities Act, 2016.
The SHRC partly upheld the complaint and awarded compensation, mainly due to the illegal arrest by the police, while dismissing allegations against prison officials. Dissatisfied with the relief granted, the appellant filed a writ petition before the Madras High Court. The High Court increased the compensation and issued directions to State authorities. However, the appellant argued that the relief was still not enough and did not adequately address the seriousness and ongoing nature of the violations. He then approached the Supreme Court of India through a Special Leave Petition under Article 136 of the Constitution.
ISSUES RAISED
The Supreme Court considered the following issues:
Whether failure to provide reasonable accommodation and disability-specific facilities to a prisoner violates Article 21 of the Constitution of India.1
Whether the provisions of the Rights of Persons with Disabilities Act, 2016 are applicable to prisons and custodial institutions.
Whether the compensation awarded by the High Court was adequate for the violation of the appellant’s fundamental and statutory rights.
ARGUMENTS OF THE PARTIES
ARGUMENTS OF THE APPELLANT
The appellant argued that the right to life guaranteed under Article 21 of the Constitution includes the right to live with dignity, access to health care, and humane treatment. He contended that these rights also apply to prisoners and are not lost during imprisonment, except where legally restricted.
The appellant stated that the Rights of Persons with Disabilities Act, 2016 requires the State to ensure non-discrimination and reasonable accommodation for people with disabilities. He argued that prisons, as State institutions, must follow the Act and cannot be exempt from its rules.
He further claimed that the lack of accessible infrastructure, assistive equipment, physiotherapy, and specialized medical care led to indirect discrimination against him. The appellant emphasized that this neglect was not a one-time issue but showed a systemic failure by prison authorities.
Additionally, the appellant argued that the compensation from the High Court was not enough given his prolonged suffering, declining health, and violations of his rights.
ARGUMENTS OF THE RESPONDENTS
The State of Tamil Nadu argued that the appellant received basic medical care while in prison and that no intentional act was committed to infringe on his rights. They claimed that prisons operate under limitations and cannot provide individualized facilities beyond what they can manage.
The respondents also stated that the High Court had already increased the compensation from the SHRC and that the Supreme Court should not interfere further. They argued that prisoners’ needs must be balanced with institutional limitations and security concerns.
JUDGMENT / FINAL DECISION
The Supreme Court dismissed the appeal and upheld the Madras High Court’s judgment in full. The Court determined that no further increase in compensation was justified, noting that the appellant had already received ₹5,25,000 as per the High Court’s orders.
The Court recognized that while the appellant’s arrest was illegal and warranted compensation, the evidence did not show any deliberate violation of his rights by prison officials. It highlighted that the appellant had been placed in the prison hospital, received medical care and dietary support, and that the noted deficiencies were institutional rather than malicious.
In addition to affirming the compensation awarded, the Supreme Court directed State authorities to ensure the effective implementation of the Rights of Persons with Disabilities Act, 2016 within prisons and other custodial facilities. The Court stressed that prison authorities must continue to protect the dignity, health, and rights of prisoners with disabilities, and that constitutional and statutory protections remain in effect even during incarceration.2
LEGAL REASONING / RATIO DECIDENDI
The Supreme Court based its reasoning on Article 21 of the Constitution, which guarantees the right to life and personal liberty. The Court reiterated that prisoners do not lose their fundamental rights upon incarceration, except where lawfully limited by imprisonment.3 The right to live with dignity, the Court stated, is a key part of Article 21 and is not reduced by custody.
The Court held that access to health care, humane living conditions, and protection from cruel or degrading treatment are essential parts of the right to life. Denying these basic needs, especially for persons with disabilities, could violate Article 21, given the State’s increased duty of care towards individuals in custody.
A crucial aspect of the Court’s reasoning was recognizing that the Rights of Persons with Disabilities Act, 2016 applies to custodial institutions, including prisons.4 The Court rejected the idea that prisons are exempt from the Act and clarified that reasonable accommodations are a legal obligation, not just a matter of administrative choice.
However, the Court also stated that institutional limitations, when not accompanied by deliberate neglect or malice, do not automatically breach Article 21 or the RPwD Act. In this case, the Court found that the appellant received hospitalization, medical care, and dietary support while in custody, and that no intentional violations by prison authorities were shown.
Regarding compensation, the Court stressed that remedies for violations of fundamental rights need to be effective and proportional to the harm suffered. Since the High Court already granted suitable compensation for the illegal arrest, the Supreme Court saw no need for further increases.
CONCLUSION
The decision in L. Muruganantham v. State of Tamil Nadu & Others is an important addition to Indian law, particularly regarding prison management and disability rights. Although the Supreme Court did not change the compensation given by the Madras High Court, the ruling plays a more significant role by clarifying the legal standards for treating people with disabilities in custody. It reaffirms that being incarcerated does not strip individuals of their dignity or constitutional rights, especially when they rely entirely on the State for care, medical attention, and basic living conditions.
A key strength of the judgment is its careful distinction between personal responsibility and systemic accountability. In this case, the Court found no intentional violation of the appellant’s rights by prison authorities. It noted that the individual was housed in the prison hospital and received medical and nutritional support within the available facilities. However, the Court did not accept infrastructure issues as a blanket excuse against constitutional review. By taking this stance, the Court maintained that minimum standards of humane treatment and accessibility are essential constitutional requirements without expecting perfection.
Equally important is the Court’s clear statement that the Rights of Persons with Disabilities Act, 2016 applies fully to custodial institutions, including prisons. By rejecting any implied exemption for prisons, the ruling strengthens the legal framework for disability rights and clarifies that reasonable accommodation is a legal requirement, not just an administrative choice. This is especially crucial in the prison context, where people with disabilities represent one of the most vulnerable groups and often struggle to advocate for themselves.
The broader significance of the judgment lies in its systemic recommendations aimed at reforming prisons. Even while rejecting the appeal on its substance, the Supreme Court acknowledged the ongoing structural problems in Indian prisons, particularly regarding accessibility, staff training, and data collection on prisoners with disabilities. The Court’s guidance marks a shift from a solely reactive approach to a more proactive and reform-minded view of constitutional governance. Although these suggestions are technically not binding, they are likely to shape future legal cases, administrative policies, and oversight of prisons.
In summary, L. Muruganantham carefully balances the enforcement of fundamental rights with the realities of institutional constraints. It avoids judicial overreach while reaffirming the State’s obligations under Article 21 and the RPwD Act. The judgment serves as an important precedent for future cases involving the rights of individuals with disabilities in custody and contributes significantly to the ongoing discussion about humane and inclusive prison management in India.
Reference(S):
1India Const. art. 21 (India).
2 L. Muruganantham v. State of Tamil Nadu & Others (2025) 10 SCC 401 (India).
3 Sunil Batra v. Delhi Administration, (1978) 4 SCC 494 (India).
4 Rights of Persons with Disabilities Act, No. 49 of 2016 (India).
