In a landmark move aimed at strengthening disability rights within India’s correctional system, the Supreme Court of India has issued pan-India directions to ensure that prisoners with disabilities are treated with dignity and provided with full accessibility in line with the Rights of Persons with Disabilities Act, 2016 (RPwD Act). The judgment, pronounced by a Bench comprising Justice Vikram Nath and Justice Sandeep Mehta, marks a significant advancement in disability-inclusive governance and prison reforms.
The order was delivered while hearing a Public Interest Litigation (PIL) filed by Sathyan Naravoor, who highlighted the lack of adequate facilities and legal protections for inmates with physical, sensory, cognitive, and mental disabilities. The Supreme Court held that prison conditions across India remain “deficient” in addressing the needs of disabled inmates and called for urgent nationwide reforms.
Background: The Muruganantham Guidelines Now Made Applicable Across India
During the proceedings, the Bench referred to the earlier judgment in L. Muruganantham v. State of Tamil Nadu, where the Court had framed extensive disability-inclusive guidelines for Tamil Nadu prisons. These guidelines included directives on accessibility, rehabilitation, therapeutic services, infrastructure standards, and protection mechanisms for inmates with disabilities.
Recognizing that disability rights cannot be limited to one State, the Court formally extended these guidelines to all States and Union Territories, making disability-friendly prison reforms a national mandate.
This ensures that the standards already accepted as constitutionally necessary in one State will now serve as the benchmark for all correctional institutions across India.
Supreme Court’s Observation: Lack of RPwD Act Implementation in Prisons
The Bench noted that despite the RPwD Act being in force since 2016, prison manuals in many States still lack mandatory provisions for accessibility and disability support. These include:
- Ramps and wheelchair-friendly spaces
- Accessible toilets and bathing facilities
- Availability of mobility aids
- Access to therapy and rehabilitation
- Disability-sensitive administrative procedures
The Court emphasized that failure to implement the RPwD Act violates constitutional guarantees under Articles 14, 19, and 21, as well as India’s obligations under the UN Convention on Rights of Persons with Disabilities (UNCRPD).
Key Supreme Court Directions: A Comprehensive Disability-Inclusive Prison Framework
The judgment lays down a wide range of directives that aim to transform the prison ecosystem into a dignified, accessible, and rights-based environment for disabled inmates.
1. Nationwide Adoption of the Muruganantham Framework
All States and UTs must ensure:
- Wheelchair-accessible pathways and cells
- Accessible toilets, ramps, and tactile signage
- Availability of physiotherapy and occupational therapy
- Disability-appropriate diets
- Trained staff for handling inmates with physical and cognitive disabilities
This creates, for the first time, a uniform national standard for disability-friendly prisons.
2. Accessible Grievance Redressal Mechanism
The Court mandated the creation of a separate grievance system tailored for prisoners with disabilities. The mechanism must be:
- Accessible in physical, digital, and sign-language formats
- Free from intimidation or retaliation
- Monitored by independent authorities
This ensures that disabled inmates can safely report abuse, neglect, or denial of facilities.
3. Inclusive Education for All Prisoners
The Bench held that no inmate can be denied education due to disability, whether physical, sensory, or learning-related.
Prisons must provide:
- Assistive learning tools
- Modified study materials
- Braille, audio-based, or large-print resources
- Support for persons with intellectual disabilities
This directive aligns with the RPwD Act’s mandate for reasonable accommodation in educational spaces.
Section 89 RPwD Act: Penal Provisions Now Bind Prison Authorities
In a major move toward accountability, the Supreme Court declared that the penal consequences under Section 89 of the RPwD Act—which imposes fines up to ₹5 lakh for violating disability rights—shall now apply mutatis mutandis to prisons.
This means prison officers, superintendents, and related authorities may now face penalties for:
- Neglect
- Discrimination
- Denial of accessibility
- Abuse or ill-treatment of disabled prisoners
The Court also directed States to run awareness programmes for prison staff regarding the penalties under Section 89.
Assistive Devices: Detailed Plans Required from States
Recognizing both the need and the security concerns associated with mobility aids inside prisons, the Bench asked all States and UTs to submit detailed plans outlining:
- Procurement of assistive devices
- Assessment systems for individual inmates
- Maintenance and replacement procedures
- Safety protocols
- Storage and handling mechanisms
The goal is to ensure that disabled prisoners are not deprived of essential aids such as wheelchairs, crutches, walkers, hearing devices, and communication tools.
Enhanced Visitation Rights for Prisoners with Benchmark Disabilities
The Court noted that emotional support is crucial for rehabilitating persons with disabilities. Therefore, it directed the States to create more accessible and compassionate visitation rules, ensuring that inmates with benchmark disabilities receive:
- Longer or more frequent visits
- Barrier-free visitation spaces
- Assistance for mobility during visitation
- Access to video-conferencing options when needed
These provisions must balance prison security with humane treatment.
Compliance Reports Due by April 7, 2026
To ensure implementation, the Supreme Court directed all States and UTs to file comprehensive compliance reports within four months. These reports must include:
- Steps taken to implement Muruganantham and new directives
- Current status of accessibility in prisons
- Procurement plans for assistive devices
- Frameworks for education and grievance redressal
The matter has been listed for April 7, 2026, when the Court will review nationwide compliance.
Significance of the Judgment: A Turning Point for Disability Rights Inside Prisons
This judgment is a watershed moment in the enforcement of the Rights of Persons with Disabilities Act, 2016, especially inside a closed institutional environment like prisons, where rights violations often remain invisible.
The ruling:
- Strengthens constitutional rights
- Promotes humane treatment
- Ensures accessibility and reasonable accommodation
- Brings accountability through Section 89 RPwD Act
- Aligns India’s prison system with global disability standards
It reinforces the principle that disability rights do not stop at the prison gates.
Conclusion
By extending the Muruganantham guidelines nationwide and adding substantial new directions, the Supreme Court has laid the foundation for a comprehensive, rights-based, disability-inclusive prison system. The judgment ensures that the RPwD Act’s protections reach some of the most marginalized individuals—prisoners with disabilities—and sets an important precedent for future reforms in India’s criminal justice system.
Also Read
