Case Note & Summary
The Supreme Court, in a public interest litigation regarding inhuman conditions in 1382 prisons, addressed the issue of unnatural deaths of prisoners. The PIL was initiated after a letter from former Chief Justice R.C. Lahoti highlighting overcrowding, unnatural deaths, staff inadequacy, and lack of training was treated as a writ petition. In an earlier order dated 5th February 2016, the Court had issued directions concerning overcrowding. In the present stage of the proceedings, the Court considered the problem of unnatural deaths in prisons. The only available data was from the National Crime Records Bureau (NCRB), which showed that between 2012 and 2015, there were a significant number of deaths in judicial custody, with a small fraction classified as unnatural. The Amicus Curiae pointed out that the NCRB's classification of natural versus unnatural deaths was unclear, as deaths resulting from lack of proper or timely medical attention could arguably fall into either category. The Court agreed that the distinction needed explanation and indicated that it would address this issue. The judgment also reiterated that custodial violence, whether physical, psychological, or sexual, is abhorrent and violative of Article 21 of the Constitution, which guarantees the dignity of the individual. The Court emphasized that authorities must display greater sensitivity towards persons in custody. The order did not contain a final disposal of the issue but set the stage for further directions.
Headnote
A) Constitutional Law - Fundamental Rights - Custodial Violence - Article 21, Constitution of India - The Court observed that custodial violence could manifest as psychological or sexual violence, and emphasized that the dignity of the individual is paramount; authorities must be sensitive to the vulnerable condition of prisoners. (Paras 1-2) B) Prison Law - Unnatural Deaths in Custody - NCRB Death Classification - The Court noted that the NCRB's distinction between natural and unnatural deaths was ambiguous, especially in cases where lack of timely medical attention led to death, and required an explanation for the classification methodology. (Paras 6-7)
Issue of Consideration
Unnatural deaths of prisoners and the need to clarify the National Crime Records Bureau's (NCRB) classification of natural and unnatural deaths in judicial custody.
Law Points
- custodial violence
- including psychological and sexual violence
- is abhorrent
- Article 21 guarantees dignity of individual
- authorities must be sensitive to prisoners' rights
- unnatural deaths in prisons must be addressed
- NCRB classification of natural and unnatural deaths needs clarification
