Access to clean, hygienic sanitation in court complexes is a fundamental right to dignity under Article 21.

The petitioner filed a writ petition highlighting the poor maintenance and upkeep of female washrooms at the Saket District Court Complex

The Court subsequently expanded the scope of the petition to include all District Court Complexes in Delhi and appointed a Court Commissioner to inspect these facilities

Reports from the Court Commissioner and the Public Works Department (PWD) revealed systemic inadequacies in sanitation infrastructure

The PWD provided timelines for the completion of renovation and construction projects, specifically citing September 30, 2025, for Dwarka Courts and March 31, 2026, for Saket Courts

1. Whether the failure to maintain clean and functional sanitation facilities in court complexes violates the fundamental right to dignity and health under Article 21 of the Constitution

2. Whether statutory authorities can avoid the obligation to provide basic sanitation on the grounds of financial or administrative limitations

The Court primarily applied Article 21 of the Constitution, which guarantees a life of dignity rather than mere animal existence

It relied on *Municipal Council, Ratlam v. Vardichan*, establishing that basic sanitation is a constitutional responsibility and statutory bodies cannot plead financial inability to avoid abating public nuisances

The Court further applied the principles from *Suchita Srivastava v. Chandigarh Administration* regarding bodily integrity

Justice K.S. Puttaswamy (Retd.) v. Union of India* regarding privacy as an intrinsic part of liberty

Consumer Education and Research Centre v. Union of India* regarding the right to health as a facet of Article 21

The Court reasoned that court complexes are "Constitutional spaces" where the infrastructure must reflect minimum standards of human dignity

Applying the *Ratlam* precedent, the Court emphasized that sanitation is not "charity" but a binding obligation that the state cannot bypass through pleas of "poor finance"

The Court specifically noted that inadequate facilities create a "subtle but real barrier" to the equal participation of women in the justice system, thus implicating Articles 14 and 15

The Court linked the biological realities of women to the requirement of functional institutional arrangements, concluding that clean washrooms are foundational requirements of a functional justice system, not peripheral amenities

While disposing of the petition based on the PWD's assurances to complete work within the stipulated timelines

the Court issued a standing direction that any future grievances must first be addressed to the respective Principal District Judge for administrative action against the PWD or Bar Associations

The Court recorded the PWD's commitment to maintain hygiene and granted the petitioner liberty to file a fresh petition if circumstances warrant