Full Judgment Text
2026 INSC 397
REPORTABLE
IN THE SUPREME COURT OF INDIA
CIVIL ORIGINAL JURISDICTION
WRIT PETITION (CIVIL) NO(S). 182 OF 2025
SATHYAN NARAVOOR ….PETITIONER(S)
VERSUS
UNION OF INDIA & ORS. ….RESPONDENT(S)
O R D E R
Mehta, J.
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
1
Act, 2016 , and the constitutional guarantees of
dignity, equality, and non-discrimination are being
effectively realised in custodial settings, and whether
Signature Not Verified
Digitally signed by
SHIPRA NARANG
Date: 2026.04.21
17:43:54 IST
Reason:
1
For short, “RPwD Act, 2016”
1
adequate mechanisms exist to secure their
meaningful implementation.
nd
2. This Court, vide order dated 2 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
2
Others . 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.
2
(2025) 10 SCC 401.
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WRIT PETITION (CIVIL) NO(S). 182 OF 2025
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
L. Muruganantham (supra) as well as those
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WRIT PETITION (CIVIL) NO(S). 182 OF 2025
nd
mandated vide order dated 2 December, 2025 in the
present proceedings. The relevant extracts from the
said order are reproduced hereinbelow: -
“ 9. We have considered the above submissions
advanced by Mr. Kaleeswaram Raj, learned counsel
representing the petitioner. Learned counsel for the
Union of India and respective States do not object to
the inclusion of more directions in addition to those
already given in L. Muruganantham (supra) .
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: -
A. The directions issued by this Court in L.
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.
B. Every State and Union Territories shall
establish a robust, independent and accessible
grievance redressal mechanism specifically
designed for prisoners with disabilities. The
said mechanism shall ensure prompt
registration, effective monitoring and timely
resolution of complaints, so as to safeguard
inmates from systemic neglect, abuse and
discriminatory practices.
C. Appropriate facilities shall be created to ensure
that prisoners with disabilities have
meaningful access to inclusive education
within the prison system. No inmate shall be
deprived of the opportunity to pursue
educational programmes solely on account of
disability, and suitable adjustments shall be
made to facilitate their effective participation.
D. Section 89 of the RPwd Act shall mutatis
mutandis be made applicable to prison
establishments across the country. All prison
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WRIT PETITION (CIVIL) NO(S). 182 OF 2025
authorities shall take adequate steps to
disseminate awareness of the obligations
flowing from the said provision to all officers,
staff, legal-aid personnel, and other
stakeholders.
E. Learned counsel appearing for the petitioner
has sought directions for the provision of
appropriate assistive devices, mobility aids,
and other support equipment to prisoners with
disabilities. However, considering the crucial
issue relating to prison security and the
practical modalities of implementation, we, for
the present, deem it appropriate to call upon
all States and Union Territories to indicate in
its compliance report the structured
institutional mechanism proposed to ensure
the regular availability, maintenance, and
secure provision of assistive devices, mobility
aids, and other disability-support equipment
for prisoners with disabilities. The affidavit
shall clearly outline the procedures,
infrastructure, procurement systems,
supervision protocols, and security measures
by which such assistive aids will be made
accessible to inmates, enabling them to carry
out their daily activities with dignity without
compromising institutional safety.
F. Prisoners with benchmark disabilities shall be
entitled to enhanced visitation provisions, in
order to ensure sustained family support,
emotional well-being, and continuous
monitoring of their special needs. The specific
modalities for such visitation shall be framed
by the concerned departmental head of each
State and Union Territory so as to balance
security considerations with the imperative of
accessibility and humane treatment.
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
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WRIT PETITION (CIVIL) NO(S). 182 OF 2025
undertaken for effectuating the directions issued in
L. Muruganantham (supra) as well as those
mandated herein. The report shall clearly set out the
steps adopted, the progress achieved, and the
modalities evolved for ensuring faithful
implementation of the aforesaid directions in the
prisons located within their jurisdictions.”
4. Thereafter, the matter came up for hearing on
th
8 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 &
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WRIT PETITION (CIVIL) NO(S). 182 OF 2025
3 th
Ors. , vide its judgment dated 26 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 expert-
driven 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
3
2026 SCC OnLine SC 317.
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WRIT PETITION (CIVIL) NO(S). 182 OF 2025
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: -
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WRIT PETITION (CIVIL) NO(S). 182 OF 2025
A. The Secretary, Department of Empowerment of
Persons with Disabilities, Union of India (or his
nominee not below the rank of Additional
Secretary), shall forthwith start active
participation in the proceedings before the
High-Powered Committee.
B. The Secretaries of the Department of Social
Justice and Empowerment/Department of
Social Welfare of all States and Union Territories
(or their nominees not below the rank of
Additional Secretary) shall also join the
proceedings and ensure effective representation
before the High-Powered Committee with
immediate effect.
C. All the States and Union Territories shall place
their compliance affidavits before the High-
Powered Committee within a period of six
weeks from the date of this order.
D. The petitioners as well as the intervenor(s) are
permitted to participate in the proceedings
before the High-Powered Committee and shall
be at liberty to file their representations along
with any relevant material, before it. The High-
Powered Committee shall duly consider such
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WRIT PETITION (CIVIL) NO(S). 182 OF 2025
representations in accordance with law while
discharging its mandate.
E. The High-Powered Committee shall ensure due
and effective compliance by all States and Union
Territories with the directions issued by this
Court in L. Muruganantham (supra) , as well
nd
as those mandated vide order dated 2
December, 2025 in the present proceedings. For
the said purpose, it shall be empowered to issue
such directions to the concerned departments
of the States/Union Territories, as may be
necessary for effective implementation.
F. The High-Powered Committee shall formulate a
comprehensive and implementable action plan
for the provision of appropriate assistive
devices, mobility aids, and other necessary
support equipment to prisoners with
disabilities, ensuring that such measures are
tailored to their specific needs and functional
requirements. The said action plan shall also lay
down uniform standards, modalities of
procurement, maintenance protocols, and
safeguards, while duly taking into account the
security considerations inherent in prison
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WRIT PETITION (CIVIL) NO(S). 182 OF 2025
administration, so as to facilitate its effective
and consistent adoption by all the States and
Union Territories.
G. The High-Powered Committee shall be at liberty
to seek assistance from expert institutions,
specialised bodies, and organisations working
in the field of persons with disabilities, and may
engage with domain experts, civil society
organisations, and other stakeholders, as may
be required, for the effective and informed
discharge of its functions. The expenses
incurred in this exercise shall be borne by the
Ministry of Social Justice and Empowerment,
Union of India as may be directed by the High-
Powered Committee.
H. The Chairperson of the High-Powered
Committee shall devise appropriate modalities
governing its functioning and schedule of
meetings, so as to suitably delineate and, where
necessary, segregate its consideration of issues
pertaining to Open Correctional Institutions
from those arising in the present proceedings,
ensuring focused and effective examination of
both domains.
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WRIT PETITION (CIVIL) NO(S). 182 OF 2025
I. The High-Powered Committee shall, as far as
feasible within a period of four months , submit
a consolidated status report before this Court
indicating the progress made, challenges
encountered, and further measures proposed
for ensuring full compliance with the directions
issued by this Court.
J. All the States and Union Territories shall extend
full cooperation to the High-Powered Committee
and ensure that all requisite data, records, and
logistical support are made available to it in a
timely manner.
8. The Registry is directed to forthwith transmit a
copy of this order to the Hon’ble Chairperson of the
High-Powered Committee for necessary compliance.
9. Before parting, it is necessary to emphasise that
the directions issued herein are firmly grounded in
the constitutional guarantees of dignity, equality,
and substantive justice. The rights of prisoners with
disabilities must be recognised and effectuated in a
manner that accords with a humane, rights-based
approach, ensuring that incarceration does not, in
any manner, dilute or abridge the fundamental
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WRIT PETITION (CIVIL) NO(S). 182 OF 2025
protections enshrined under Articles 14 and 21 of the
Constitution. The concerned authorities are,
therefore, duty-bound to ensure faithful and effective
implementation of these directions, in both letter and
spirit.
st
10. List this matter on 1 September, 2026, along
with Writ Petition (Civil) No. 1082 of 2020 (Suhas
Chakma v. Union of India & Ors.) .
….……………………J.
(VIKRAM NATH)
...…………………….J.
(SANDEEP MEHTA)
NEW DELHI;
APRIL 21, 2026.
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WRIT PETITION (CIVIL) NO(S). 182 OF 2025