After Undertrial Dies In Ajmer Jail, Rajasthan HC Sets 3-Month Deadline For Statewide Prison CCTV Upgrades

In brief

The question

1. Whether the State had achieved sufficient compliance with earlier directions and reforms concerning prison conditions and prisoner welfare, or whether further directions were required

The court held

The Court closed and disposed of the batch of PILs, while constituting a State-Level Monitoring Committee chaired by the District Judge concerned, with the Director General of Prisons, Member Secretary of RSLSA and Director of DOIT as members.

It also directed

It directed DOIT and RISL to address maintenance requests and, within three months, ensure installation and repair of specified CCTV systems and functional storage and backup; required an SOP and institution-wise logs for periodic surprise searches; and directed assessment and time-bound recruitment of Challani Guards and compliance with Phool Kumari on prisoner wages.

The State was also directed to ensure functional sanitary-napkin vending machines in women’s prisons, finalize the policy on meetings between closely related convicts within two months, and notify the Rajasthan Custodian Death Relief Scheme 2025 within three months.

The Committee must meet quarterly to review these directions and the Court’s earlier orders.

01Facts

The High Court considered a batch of public-interest petitions, initiated between 2008 and 2026, concerning prison conditions, infrastructure, security, prisoner welfare and custodial deaths in Rajasthan.

pp. 5–6 · ¶ 1–5

The proceedings included concerns about prison mobile-phone access, water and hygiene, women prisoners’ welfare, prisoner wages and implementation of earlier court directions.

pp. 6, 10–12 · ¶ 5, 9

On 29 June 2026, undertrial prisoner Jagan Gurjar was found dead in a cell at Ajmer High Security Jail; the State’s status report stated that the camera covering the cell had been offline since 24 June 2026.

pp. 7–9 · ¶ 6–8

The Court also considered reports identifying deficiencies in CCTV coverage, staffing, security searches and other prison facilities, alongside the State’s account of reforms and compliance.

pp. 10–12 · ¶ 9

02Issues

i.1. Whether the State had achieved sufficient compliance with earlier directions and reforms concerning prison conditions and prisoner welfare, or whether further directions were required

pp. 10–12 · ¶ 9–11

ii.2. Whether continuing judicial oversight was necessary to address prison security and infrastructure deficiencies, including non-functional or inadequate CCTV systems

pp. 9–13 · ¶ 8–9, 11–13

iii.3. Whether the pending PIL proceedings could be closed while preserving an effective mechanism for monitoring compliance

p. 13 · ¶ 12

03Law Applied

The Court relied on its earlier directions in the lead petition, including the directions dated 27 January 2016 and 5 March 2018, which required prison reforms and security measures, and ordered continued compliance with them.

pp. 10, 13–14 · ¶ 9, 13–14

It referred to Phool Kumari v. Superintendent, Central Jail, Tihar, New Delhi, 2012 Cr LJ 1261 (SC), in connection with prisoner wages, and directed that wages remain in consonance with that decision.

p. 6, 14 · ¶ 5, 13(iv)

The Court also noted the Rajasthan Prisoners Rules 2022, Parole Rules 2021 and Shortening of Sentences Rules 2026 as reforms reported by the State.

p. 10 · ¶ 9(a)

The judgment did not set out a separate statutory test; its operative principle was that prison reforms and prior judicial directions require continuing, verifiable implementation, rather than episodic or merely reported compliance.

pp. 12–13 · ¶ 11–12

04Reasoning

The Court acknowledged substantial institutional reforms but found that the Ajmer death and reported camera, staffing and security-search deficiencies demonstrated the need for effective and continuing implementation.

pp. 12–13 · ¶ 11–12

It accepted that the Ajmer camera failure had been reported as a technical fault and that the Superintendent had made repeated maintenance requests, but treated the broader gaps in CCTV coverage and maintenance as requiring time-bound action.

pp. 9–10 · ¶ 8–9

Because the State was pursuing reforms, the Court considered that keeping the PILs pending indefinitely would serve no further useful purpose; closure was therefore made conditional on a permanent monitoring mechanism and specific compliance directions.

p. 13 · ¶ 12–14