The Supreme Court on July 15 clarified that all prisoners, including those with disabilities, do not have a fundamental right to demand personal or expensive food items like chicken, eggs or nuts daily. The court said prisons should be humane and inclusive, but they are correctional institutions - not extensions of civic amenities.
A bench of Justices JB Pardiwala and R Mahadevan, while considering prison rules in Tamil Nadu, said:
"Prisons are correctional institutions - not extensions of civic amenities. Non-supply of non-essential or luxury items is not a constitutional or human rights violation unless it causes manifest injury to health or dignity."
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The court was dealing with a petition filed by a disabled lawyer who was arrested in a civil dispute. He alleged custodial torture and complained that prison authorities failed to provide him with a protein-rich diet and adequate medical treatment.
He approached the Tamil Nadu Human Rights Commission, which held his arrest illegal and ordered disciplinary action against the police as well as a compensation of ₹1 lakh. The commission, however, dismissed his complaint against the prison authorities, saying there was no violation of human rights in the prison.
Later, the Madras High Court enhanced the compensation to ₹5 lakh, but also said there was no constitutional violation by the prison authorities.
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The Supreme Court upheld the High Court's findings, saying:
"Mere non-supply of favourite or expensive food items cannot be treated as a violation of fundamental rights."
"The State has an obligation to ensure that every prisoner, including the disabled, receives adequate, nutritious and medically appropriate food, subject to medical certification."
Writing the judgment, Justice R. Mahadevan said the issues raised by the petitioner arose from institutional limitations and not from willful neglect or malafide on the part of prison staff. The Court emphasised that lack of resources cannot be equated with a violation of rights.
However, the Court expressed concern over the conditions of prisons and highlighted the need for disability-sensitive reforms:
“This Court expresses deep concern at the plight of persons with disabilities, who are among the most marginalised and vulnerable groups within the justice system.”
It pointed to the absence of legal or policy frameworks that ensure dignity, access and protection for prisoners with disabilities and the transgender community. Structural barriers in prisons, such as the absence of accessible toilets or trained carers, often deprive them of dignity and basic care.
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The Court also noted the serious lack of disaggregated statistics on prisoners with disabilities and stated:
“Lawful imprisonment does not suspend the right to human dignity. Punishment consists only in the restriction of liberty – not in the deprivation of humane treatment or proper facilities.”
Case Title: L. Muruganantham vs State of Tamil Nadu & Ors
SLP (C) No: 1785/2023