SATHYAN NARAVOOR Vs. UNION OF INDIA

JUDGEMENT

(1.) The present proceedings bring to the fore issues of considerable importance concerning the rights, conditions of detention, and institutional safeguards available to prisoners with disabilities within prison systems across the country. The matter necessitates a closer examination of the extent to which the mandate of the Rights of Persons with Disabilities Act, 2016 [For short, "RPwD Act, 2016"], and the constitutional guarantees of dignity, equality, and non-discrimination are being effectively realised in custodial settings, and whether adequate mechanisms exist to secure their meaningful implementation.

(2.) This Court, vide order dtd. 2/12/2025, noted that the grievances raised by the petitioner herein stand substantially ventilated by the directions issued by this Court in L. Muruganantham v. State of Tamil Nadu and Others [ (2025) 10 SCC 401.]. In the said decision, this Court laid down an 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, 2016 and constitutional guarantees.

(3.) However, having regard to the submissions advanced by learned counsel appearing for the petitioner, this Court deemed it appropriate to issue certain further directions, in addition to those contained in L. Muruganantham (supra). In brief, this Court directed that the directions issued in L. Muruganantham (supra) be extended to all States and Union Territories; that a robust, independent and accessible grievance redressal mechanism be established for prisoners with disabilities; that facilities for inclusive education be ensured; that the provisions of Sec. 89 of the RPwD Act, 2016 be made applicable to prison establishments, along with appropriate awareness and sensitisation measures; that the States and Union Territories indicate structured mechanisms for the provision of assistive devices and support equipment; and that enhanced visitation rights be extended to prisoners with benchmark disabilities. It was further directed that all States and Union Territories shall file comprehensive compliance reports within the stipulated period, clearly indicating the measures undertaken for effectuating the directions issued in L. Muruganantham (supra) as well as those mandated vide order dtd. 2/12/2025 in the present proceedings. The relevant extracts from the said order are reproduced hereinbelow: -