National Alliance for People's Movements & Ors. v. The State of Maharashtra & Ors.

Special Leave Petition (Criminal) · 2020 INSC 558Decided 22 Sept 2020
Special Leave Petition (Criminal) No. 4116 of 2020
Chief Justice S.A. Bobde · Justice A.S. Bopanna · Justice V. Ramasubramanian

Background

Following the Supreme Court's earlier COVID-19 directions to decongest overcrowded prisons, Maharashtra's High-Powered Committee classified prisoners into categories for interim bail/parole eligibility, broadly excluding those convicted of more serious or special-law offences (like economic offences, MCOC, PMLA, NDPS and UAPA cases) and those with sentences above seven years. A public-interest petitioner challenged this classification as discriminatory before the Bombay High Court, which largely upheld it, leading to this Special Leave Petition before the Supreme Court.

Decision Breakdown

The Supreme Court upheld the High Court's decision, holding that the classification made by the High-Powered Committee was a reasonable one under Article 14's equality principles, since prisoners facing serious or specially-regulated offences are not similarly situated to those facing lesser charges. It emphasised that this emergency interim-bail mechanism was never meant to be a universal right to release for all prisoners regardless of offence, but a calibrated tool to relieve overcrowding while still accounting for public safety and the severity of the underlying offence. The Court also noted that Maharashtra had already released over 10,000 prisoners and set up temporary facilities, showing the scheme was being implemented in good faith, and it left open the door for individual prisoners facing genuine discrimination within their own category to seek relief separately.

Lesson Learnt

Emergency relief measures (like COVID-era prison decongestion) can validly treat different categories of offenders differently based on the severity of their crime without violating equality principles: "equal treatment" does not mean identical treatment for everyone regardless of circumstances.

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