The Supreme Court on Tuesday delivered a significant order that could reshape living conditions for prisoners with disabilities across India. During a brief but intense hearing, the bench of Justice Vikram Nath and Justice Sandeep Mehta signaled that the court was no longer willing to accept piecemeal reforms. Instead, it extended previously issued disability-rights directives to every State and Union Territory, saying that “uniform dignity cannot depend on geography.”
Background
The petition, filed by Sathyan Naravoor under Article 32 as a public interest case, highlighted what his counsel called “a deep and constant neglect of disabled inmates.” He pointed out that several prison manuals still fail to include mandatory accessibility features-ramps, assistive devices, accessible toilets-despite clear provisions in the Rights of Persons with Disabilities (RPwD) Act, 2016.
During the hearing, the court took note of its earlier ruling in L. Muruganantham, where Tamil Nadu prisons were directed to overhaul infrastructure and services for inmates with disabilities. The bench remarked that most of the grievances raised here had already been addressed in that judgment.
But the petitioner argued that “the problem is national, not regional,” and requested that those directives be extended to all States and UTs. He also sought additional measures, including inclusive education for PwD inmates, a grievance system, and clarity on the applicability of Section 89 of the RPwD Act, which prescribes penalties for violations.
Court’s Observations
The judges appeared largely convinced that systemic reforms were overdue. At one point, Justice Mehta observed, “If the law promises equal treatment, prisons cannot be islands where rights evaporate.”
The bench referred extensively to the Muruganantham framework, reiterating the need for accessible toilets, ramps, physiotherapy spaces, disability-friendly communication formats, and trained prison staff. It agreed that these directions should not remain confined to one State.
The court also acknowledged concerns about disabled prisoners lacking avenues to complain about neglect or mistreatment. “The bench observed, ‘Without a real mechanism for grievances, rights remain ornamental.’”
On the sensitive issue of assistive devices-wheelchairs, hearing aids, mobility tools-the court noted that security implications must be balanced. Rather than ordering immediate implementation, it required States to propose a structured mechanism explaining how such devices would be made available without compromising safety.
Another notable remark came when the court addressed enhanced visitation rights. Recognizing the emotional and practical importance of family support for PwD inmates, Justice Nath stated, “Isolation worsens disability; contact sustains dignity.”
Decision
In a sweeping set of directions, the bench ordered that:
- All Muruganantham directives shall automatically apply to every State and Union Territory.
- A dedicated and accessible grievance redressal system for prisoners with disabilities must be established nationwide.
- Inclusive educational opportunities must be made available to PwD inmates, with reasonable accommodations.
- Section 89 of the RPwD Act shall apply mutatis mutandis to prison establishments, and authorities must be properly sensitised.
- States must submit detailed plans on procuring, maintaining, and securely providing assistive devices.
- Prisoners with benchmark disabilities shall receive enhanced visitation rights, with modalities to be outlined by each State/UT.
The court directed all States and UTs to submit comprehensive compliance reports within four months and listed the matter for April 7, 2026, for further review. The order ends firmly but without flourish-an unmistakable message that execution now matters more than promises.
Case Title: Sathyan Naravoor vs. Union of India & Others
Case No.: Writ Petition (Civil) No. 182 of 2025
Case Type: Public Interest Litigation (PIL) under Article 32
Decision Date: 02 December 2025