In a strong statement against constitutional violations by State authorities, the Punjab and Haryana High Court has awarded ₹3 lakh compensation to Satnam Singh, a convict detained for nine extra months beyond his lawful sentence in a narcotics case. The Court emphasized that such extended incarceration is not just a procedural lapse but a grave constitutional breach.
“State-inflicted injustice, such as unlawfully extending a person’s custody beyond the sentence imposed, is a serious breach that cannot be condoned under any circumstances,” – Justice Harpreet Singh Brar.
Background of the Case
Satnam Singh was convicted under Section 15 of the NDPS Act in connection with a 2002 FIR and sentenced to rigorous imprisonment for 1 year and 6 months, along with a ₹5,000 fine. However, he ended up spending a total of 2 years, 3 months, and 29 days in custody — an excess of over 9 months even when accounting for default imprisonment.
Justice Brar noted that such detention, beyond the trial court’s sentence, directly undermines due process and reflects disregard for judicial authority. He stated:
“When the State itself becomes the violator of liberty through negligence or apathy, it sets a dangerous precedent that erodes faith in the justice system.”
The Court criticized the failure of the District Legal Services Authority for not acting promptly to secure timely release. It was emphasized that a person’s access to justice should not depend on financial status.
“The law must be blind to wealth or status… If the appellant had been in a better financial position, he or his family could have easily afforded legal representation.”
The Court referred to landmark judgments including:
- Satender Kumar Antil v. CBI (2022): Undertrial detentions must be minimized to avoid unnecessary incarceration.
- Rudul Shah v. State of Bihar (1983): Compensation is a valid remedy for illegal detention.
- Hussainara Khatoon Case (1980): Underscored the right to legal aid and speedy trial for undertrials.
- D.K. Basu v. State of West Bengal (1997): Affirmed monetary compensation for violation of fundamental rights.
- The State government was ordered to pay ₹3 lakh compensation within eight weeks.
- A compliance report must be filed within four weeks thereafter.
- The State is allowed to recover the amount from the responsible officials.
- The appellant may still pursue civil remedies for additional damages.
The Court concluded that mere administrative excuses cannot justify constitutional violations and that such instances must invite real accountability and reform.
