Supreme Court: While considering this matter concerning the rights and conditions of detention, and institutional safeguards available to prisoners with disabilities within prison systems across the country, the Division Bench of Vikram Nath and Sandeep Mehta*, JJ., noted that the present matter necessitates closer scrutiny of the extent to which the mandate of the Rights of Persons with Disabilities Act, 2016 (RPwD Act) and the constitutional guarantees are being effectively realised in custodial settings or not.
Therefore, the Court opined that issues of the present proceedings can be more appropriately, effectively, and comprehensively addressed by the High-Powered Committee constituted by the Court in Suhas Chakma v. Union of India, 2026 SCC OnLine SC 317, for reform and governance of open correctional institutions (OCIs). The Court explained that:
“Such an approach would, in our considered view, yield manifold benefits. It would facilitate a coordinated and uniform framework across all the States and Union Territories, guided by the institutional expertise of the High-Powered Committee and informed by ground-level realities.”
The Court also issued several new directions emphasising on the need for an effective, structured, and uniform mechanism to address the issues highlighted in the present matter.
Background and Legal Trajectory
The present matter concerns the rights of disabled prisoners and their conditions during detention and in the prisons. The Court in L. Muruganantham v. State of T.N., (2025) 10 SCC 401, had held that the State bore a constitutional and moral obligation to uphold rights of disabled prisoners and issued directions for improved accessibility and care.
In December 2025, the Court in Sathyan Naravoor v. Union of India, 2025 SCC OnLine SC 2738, further laid down exhaustive framework to safeguard the rights of prisoners with disabilities, inter alia directing identification of such prisoners at the time of admission, provision of accessible infrastructure including ramps and accessible toilets, availability of healthcare and assistive devices, training and sensitisation of prison staff, conduct of accessibility audits, maintenance of disability-related data, formulation of inclusive prison manuals, establishment of monitoring mechanisms, and submission of periodic compliance reports to ensure effective implementation of the mandate of the RPwD Act and constitutional guarantees.
When the matter came up before the Court in April, it was noted that only 12 States and Union Territories have, thus far, filed their compliance affidavits.
Court’s Assessment
Noting that the present matter involved examining whether the constitutional and legislative mandates vis-a-vis prisoners and especially disabled prisoners are being realised or not, the Court was of the view that the High-Powered Committee constituted in Suhas Chakma (supra) should be undertaking this scrutiny.
The Court further opined that entrusting the issues on the present matter to the High-Powered Committee would ensure a structured, continuous, and expert driven assessment of the prevailing statutory frameworks, along with the practices and facilities extended to prisoners with disabilities across all the States and Union Territories, thereby obviating any fragmentation of proceedings and enabling a cohesive implementation of the directions already issued by the Court.
The Court further explained that the High-Powered Committee would be well placed to undertake periodic review, call for necessary reports, and evolve pragmatic solutions tailored to administrative and infrastructural constraints. Further, it would provide an accessible and specialised forum for the consideration of grievances, ensuring that issues are not only identified but also addressed in a time-bound and effective manner.
The Court also noted and explained that the functioning of the High-Powered Committee is still at a nascent stage and therefore, the incorporation of this additional mandate, being of utmost significance, would not burden its proceedings.
Directions Issued
With the above assessment, the Court thus issued the following directions:
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The Secretary, Department of Empowerment of Persons with Disabilities (or his nominee not below the rank of Additional Secretary), shall forthwith start active participation in the proceedings before the High-Powered Committee
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The Secretaries of the Department of Social Justice and Empowerment/Department of Social Welfare of all States and Union Territories (or their nominees not below the rank of Additional Secretary) shall also join the proceedings and ensure effective representation before the High-Powered Committee with immediate effect
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All the States and Union Territories shall place their compliance affidavits before the High-Powered Committee within a period of 6 weeks from the date of this order
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The petitioners as well as the intervenor(s) are permitted to participate in the proceedings before the High-Powered Committee and shall be at liberty to file their representations along with any relevant material, before it. The High-Powered Committee shall duly consider such representations in accordance with law while discharging its mandate.
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The High-Powered Committee shall ensure due and effective compliance by all States and Union Territories with the directions issued by the Court in L. Muruganantham (supra), as well as those mandated in Sathyan Naravoor (supra) dated 2 December 2025. For this purpose, High-Powered Committee shall be empowered to issue such directions to the departments concerned of the States/Union Territories, as may be necessary for effective implementation.
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The High-Powered Committee shall formulate a comprehensive and implementable action plan for the provision of appropriate assistive devices, mobility aids, and other necessary support equipment to prisoners with disabilities, ensuring that such measures are tailored to their specific needs and functional requirements. This action plan shall also lay down uniform standards, modalities of procurement, maintenance protocols, and safeguards, while duly taking into account the security considerations inherent in prison administration, so as to facilitate its effective and consistent adoption by all the States and Union Territories.
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The High-Powered Committee shall be at liberty to seek assistance from expert institutions, specialised bodies, and organisations working in the field of persons with disabilities, and may engage with domain experts, civil society organisations, and other stakeholders, as may be required, for the effective and informed discharge of its functions. The expenses incurred in this exercise shall be borne by the Ministry of Social Justice and Empowerment, as may be directed by the High-Powered Committee.
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The Chairperson of the High-Powered Committee shall devise appropriate modalities governing its functioning and schedule of meetings, so as to suitably delineate and, where necessary, segregate its consideration of issues pertaining to OCIs from those arising in the present proceedings, ensuring focused and effective examination of both domains.
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The High-Powered Committee shall, as far as feasible within a period of 4 months, submit a consolidated status report before the Court indicating the progress made, challenges encountered, and further measures proposed for ensuring full compliance with the directions issued by the Court.
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All the States and Union Territories shall extend full cooperation to the High-Powered Committee and ensure that all requisite data, records, and logistical support are made available to it in a timely manner.
Concluding Remarks
In its concluding remarks, the Court emphasised that the aforestated directions are firmly grounded in the constitutional guarantees of dignity, equality, and substantive justice. The rights of prisoners with disabilities must be recognised and effectuated in a manner that accords with a humane, rights-based approach, ensuring that incarceration does not, in any manner, dilute or infringe the fundamental protections enshrined under Articles 14 and 21 of the Constitution.
The matter was directed to be listed on 1 September 2026 along with Suhas Chakma (supra) case.
[Sathyan Naravoor v. Union of India, WRIT PETITION (CIVIL) NO(S). 182 OF 2025, order dated 21-4-2026]
*Order by Justice Sandeep Mehta
Advocates who appeared in this case:
For Petitioner(s): Mr. Kaleeswaram Raj, Adv. (VC) Mr. Mohammed Sadique T.a., AOR Ms. Thulasi K Raj, Adv. Ms. Aparna Menon, Adv. Ms. Chinnu Maria Antony, Adv.
For Respondent(s): Mrs. Aishwarya Bhati, A.S.G. Ms. Shivika Mehra, Adv. Ms. Sonali Jain, Adv. Ms. Hemandri Sharma, Adv. Mr. Rohit Ojha, Adv. Ms. Ruchi Kohli, Adv. Ms. Chitrangda Rashtravara, Adv. Mr. Alankar Gupta, Adv. Mr. Shashwat Parihar, Adv. Dr. N. Visakamurthy, AOR Mr. Alok Sangwan, Sr. A.A.G Mr. Sumit Kumar Sharma, Adv. Mr. Rajat Sangwan, Adv. Mr. Harsh Mehla, Adv. Mr. Vaibhav Yadav, Adv. Mr. Samar Vijay Singh, AOR Mr. C. K. Sasi, AOR Dr. K.K. Geetha, Adv. Ms. Meena K Poulose, Adv. Mr. Naveen Sharma, AOR Mrs. Swati Bhushan Sharma, Adv. Mr. S.K. Sharma, Adv. Ms. Payal Gola, Adv Mr. Pradeep Misra, AOR Mr. Manish Kumar, AOR Mr. Divyansh Mishra, Adv. Mr. Kumar Saurav, Adv. Ms. Ankita Sharma, AOR Mr. Arjun D Singh, Adv. Ms. Ishika Neogi, Adv. Mr. Divya Tripathi, Adv. Mr. Tushar Giri, Adv. Mr. Sahil Bhalaik, AOR Mr. Siddharth Anil Khanna, Adv. Mr. Ritik Arora, Adv. Mr. Shivam Mishra, Adv. Mr. Mihir Joshi, Adv. Ms. Disha Singh, AOR Ms. Eliza Bar, Adv. Ms. Akansha, Adv. Ms. Anjali Saxena, Adv. Ms. Deepanwita Priyanka, AOR Ms. Swati Ghildiyal, Adv. Ms. Priyal Sheth, Adv Mr. Ninad Laud, Adv. Mr. Guruprasad Naik, Adv. Mr. Dcosta Ivo Manuel Simon, AOR Mr. D K Thakur, Adv. Mr. Rajeev Kumar Gupta, Adv. Mr. Tavleen Singh, Adv. Ms. Vallabhi Shukla, Adv. Mr. Bimlesh Kumar Singh, AOR Mr. Rohit Kumar, Adv. Mr. Narendra Kumar, Adv. Mr. Sudip Lodh, Adv. Mr. Neeraj Agarwal, Adv. Mr. Jayant Mohan, AOR Ms. Meenakshi Chatterjee, Adv. Ms. Adya Shree Dutta, Adv. Mr. Aaditya Aniruddha Pande, AOR Mr. Siddharth Dharmadhikari, Adv. Mr. Shrirang B. Varma, Adv. Mr. Sourav Singh, Adv. Ms. Chitransha Singh Sikarwar, Adv. Mr. Lenin Singh Hijam, Adv. Gen, Sr. Adv. Mr. Pukhrambam Ramesh Kumar, AOR Mr. Karun Shamra, Adv. Ms. Anupama Ngangom, Adv. Ms. Rajkumari Divyasana, Adv. Mr. Avijit Mani Tripathi, AOR Mr. T.K. Nayak, Adv. Mr. Shovan Mishra, AOR Ms. Bipasa Tripathy, Adv. Mr. Shlok Luthra, Adv. Mr. Ramendra Mohan Patnaik, AOR Mr. Siddhant Sharma, AOR Mr. Vikram Choudhary, Adv. Mr. Padmesh Mishra, A.A.G. Mr. S. Udaya Kumar Sagar, AOR Mr. Sameer Abhyankar, AOR Mr. Krishna Rastogi, Adv. Mr. Aryan Srivastava, Adv. Mr. Rahul Kumar, Adv. Mr. Aakash Thakur, Adv. Mr. Ashutosh Kumar Sharma, AOR Mr. Sandeep Sharma, Adv. Mr. Deep Narayan Sarkar, Adv. Mr. G P Mahto, Adv. Ms. Devina Sehgal, AOR Mr. Yatharth Kansal, Adv. Mr. Shuvodeep Roy, AOR Mr. Deepayan Dutta, Adv. Mr. Saurabh Tripathi, Adv. Mr. Kunal Mimani, AOR Mr. Parag Chaturvedi, Adv. Ms. Swati Ghildiyal, AOR Ms. Neha Singh, Adv. Mr. Bhuvan Kapoor, Adv. Mr. Varun Chugh, Adv. Ms. Indira Bhakar, Adv. Mr. Krishna Kant Dubey, Adv. Mr. Shashwat Parihar, Adv. Mr. Mukesh Kr. Verma, Adv Mr. Shreekant Neelappa Terdal, AOR
