Sathyan Naravoor v. Union of India

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[1], and the constitutional guarantees of dignity, equality, and non-discrimination are being effectively realised in custodial settings, and whether

2. This Court, vide order dated 2nd December, 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[2]. 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 Section 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

10. In view of the aforesaid discussion, we hereby direct that, in addition to the salutary directions set out in L. Muruganantham (supra), the following directions shall also be read in conjunction with the mandate of the said judgment: -

Muruganantham (supra) shall be extended to all the States and the Union Territories, to ensure that the principles are adopted mutatis mutandis within their prison systems as well.

11. All States and Union Territories are hereby directed to place on record a comprehensive compliance report before this Court within four months from today, indicating the measures undertaken for effectuating the directions issued in

4. Thereafter, the matter came up for hearing on 8th April, 2026 for the purpose of receiving compliance reports from the States and Union Territories. On the said date, the submissions advanced by learned counsel appearing for the petitioner, as well as those representing the respective States and Union Territories, were heard at some length. It was also brought to our notice that only 12 States and Union Territories have, thus far, filed their compliance affidavits.

5. Upon bestowing our anxious and thoughtful consideration to the submissions advanced by learned counsel for the parties, we are of the considered opinion that the issues raised in the present proceedings can be more appropriately, effectively, and comprehensively addressed by the High-Powered Committee constituted by this Court in the matter of Suhas Chakma v. Union of India & Ors.3, vide its judgment dated 26th February, 2026. The High-Powered Committee, having already been entrusted with the mandate of overseeing systemic concerns relating to the harmonisation of the Rules framed by the States and Union Territories in respect of Open Correctional Institutions, is suitably equipped to examine the present issues in a holistic manner. The entrustment of the issues raised in the present matter to the High-Powered Committee would ensure a structured, continuous, and expertdriven assessment of the prevailing statutory frameworks, along with the practices and facilities extended to prisoners with disabilities across all the States and Union Territories, thereby obviating any fragmentation of proceedings and enabling a cohesive implementation of the directions already issued by this Court.

6. Such an approach would, in our considered view, yield manifold benefits. It would facilitate a coordinated and uniform framework across all the States and Union Territories, guided by the institutional expertise of the High-Powered

Committee and informed by ground-level realities. The High-Powered Committee would be well placed to undertake periodic review, call for necessary reports, and evolve pragmatic solutions tailored to administrative and infrastructural constraints. Further, it would provide an accessible and specialised forum for the consideration of grievances, ensuring that issues are not only identified but also addressed in a time-bound and effective manner. This mechanism would, thus, strengthen compliance, enhance accountability, and advance the constitutional objectives of dignity, equality, and substantive access to justice for prisoners with disabilities. We are informed that the functioning of the High-Powered Committee is still at a nascent stage and therefore, the incorporation of this additional mandate, being of utmost significance, would in no manner encumber its proceedings.

7. In view of the aforesaid discussion, and having regard to the need for an effective, structured, and uniform mechanism to address the issues highlighted in the present proceedings, we deem it appropriate to issue the following directions: -