SUHAS CHAKMA Vs. UNION OF INDIA

JUDGEMENT

(1.) The strength of a constitutional democracy is tested not merely by the liberties it guarantees in abstraction, but by the manner in which it treats those who stand at its margins, including persons deprived of their liberty with due process of law. Prisons, though instruments of lawful confinement, are not spaces where constitutional values can cease to operate. The guarantee of life and personal dignity under Article 21 of the Constitution of India extends beyond the prison gates and obliges the State to ensure that incarceration does not degenerate into inhumanity. Overcrowded prisons, bereft of humane living conditions and rehabilitative avenues, strike at the very core of this constitutional promise and call for sustained institutional response rather than sporadic remedial measures. It is within this constitutional conscience that the present proceedings have emerged.

(2.) This Court, as far back as in the year 2018, by its order dated 8th May, 2018 passed in In Re: Inhuman Conditions in 1382 Prisons, had directed all States and Union Territories to take immediate steps to align their respective prison rules with the Model Uniform Rules for the Administration of Open Correctional Institutions, and to duly adopt, notify and implement the said rules, along with undertaking appropriate measures for the effective implementation and strengthening of the framework regarding Open Correctional Institutions within their respective jurisdictions. The said proceedings continue to engage the attention of this Court and form part of an ongoing judicial endeavour to address the systemic infirmities afflicting prison administration in the country, particularly the persistent problem of overcrowding.

(3.) The figures emerging from the National Crime Records Bureau Report titled "Prison Statistics India, 2023", paints a deeply concerning picture. On a cumulative basis, prisons across the country are operating at an occupancy level of 120.8%, with several States including Madhya Pradesh, Maharashtra, Meghalaya, Uttar Pradesh and Uttarakhand as well as the National Capital Territory of Delhi, reporting occupancy levels exceeding 150%. Such chronic overcrowding is not merely an index of administrative strain, but has profound implications for human dignity, prison safety, access to healthcare, prospects of rehabilitation and adherence to the constitutional guarantees. For ready reference, the relevant table extracted from the said report is reproduced hereinbelow: -