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L. Muruganantham v. State of Tamil Nadu & Others

Civil Appeal · 2025 INSC 844Decided 15 Jul 2025
Civil Appeal No. 9487 of 2025 (arising out of SLP (C) No. 1785 of 2023)
Justice J.B. Pardiwala · Justice R. Mahadevan

Background

The appellant, a practising advocate living with an 80% locomotor disability (Becker Muscular Dystrophy) and alleged autism/mental illness, was arrested in 2020 on a complaint he says was falsely lodged by his uncle's henchman over a property dispute. He alleged mistreatment and lack of disability-appropriate food, medical care and infrastructure during his custody at Coimbatore Central Prison. His human rights complaint led the State Human Rights Commission to award Rs. 1,00,000 compensation, which the Madras High Court later enhanced to Rs. 5,00,000 along with systemic directions to the State. The appellant approached the Supreme Court seeking still higher compensation (Rs. 50,00,000) and broader enforcement.

Decision Breakdown

The Supreme Court upheld the finding that the appellant's arrest was illegal and that authorities ignored his disability status, but held that the High Court's enhanced compensation of Rs. 5,00,000 was fair, just and reasonable, declining to enhance it further. It found the prison's failure to supply certain items (e.g., protein-rich food) reflected systemic institutional limitations rather than deliberate malice, and that Article 21 does not create a right to "personalised or luxurious" food choices, only adequate and medically appropriate care. Recognising a wider pattern of neglect of disabled prisoners nationally, the Court went beyond the individual dispute and issued a detailed set of binding directions to prison authorities across India, covering accessible infrastructure, staff sensitisation training, nutritious/medically-tailored diets, regular physiotherapy/psychotherapy access, amendment of State Prison Manuals within six months, periodic monitoring committees, and disaggregated public data on disabled prisoners.

Lesson Learnt

Courts distinguish between a genuine denial of constitutionally guaranteed dignity and care (which is actionable) and a demand for preferential comforts beyond what the State is obliged to provide; but persistent systemic gaps in how India's prisons treat persons with disabilities can prompt the Supreme Court to issue nationwide reform directions even while deciding one individual's case.

Official source (sci.gov.in)View Judgment (PDF)

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