The Supreme Court has issued comprehensive nationwide directions aimed at ensuring accessibility, reasonable accommodation, and rights-based protection for prisoners with disabilities.
The Bench of Justice Vikram Nath and Justice Sandeep Mehta recently directed all States and Union Territories across the country to uniformly implement accessibility standards, create disability-responsive infrastructure, and operationalise specialised grievance-redress mechanisms for inmates with benchmark disabilities.
Delivering the verdict in Sathyan Naravoor v. Union of India & Ors, the Apex Court underscored that the constitutional guarantees under Article 21, particularly the right to dignity, remain fully operative even within custodial environments, and that prison authorities function as constitutional trustees of the rights of those deprived of personal liberty.
.The petitioner had drawn attention to persistent structural barriers faced by incarcerated persons with locomotor, visual, auditory, neuro-developmental and psychosocial disabilities, despite the statutory framework created by the Rights of Persons with Disabilities Act, 2016. By invoking key provisions of the RPwD Act, including its equality and non-discrimination mandates, it was argued that prisons continue to function without basic accessibility standards, thereby violating statutory obligations relating to reasonable accommodation and accessibility.
The petition relied on the custodial experiences of individuals such as Dr G.N. Saibaba and Fr Stan Swamy, whose disability-related needs were inadequately addressed during detention, resulting in serious health and mobility challenges. These instances had previously generated judicial concern and highlighted the systemic neglect faced by disabled prisoners. The Bench noted that inmates with disabilities were being treated in a formally identical manner to other inmates, resulting in substantive inequality—an approach inconsistent with constitutional jurisprudence on reasonable classification and with India’s commitments under the UN Convention on the Rights of Persons with Disabilities.
A significant element of the ruling lies in the Court’s decision to extend the accessibility standards laid down in L. Muruganantham v. State of Tamil Nadu (2023) to prisons across the country. The Muruganantham judgment had formulated a detailed blueprint for accessible toilets, ramps, barrier-free cells, disability-responsive prison manuals, periodic access audits, medical screening protocols and specialised training for prison staff. The Supreme Court has now held that these directions possess pan-India applicability, making them binding on all categories of prisons.
Alongside the Muruganantham framework, the Court imposed a series of new national-level requirements grounded in Articles 14, 21 and 39A of the Constitution, the RPwD Act and the Model Prison Manual, 2016. It mandated the creation of fully accessible infrastructure across all prisons, including wheelchair-friendly spaces, barrier-free corridors, accessible toilets, tactile signages and sensory-safe environments. These measures are expected to align with the Harmonised Guidelines and Standards for Universal Accessibility issued by the Ministry of Housing and Urban Affairs.
The Court also directed each State and Union Territory to establish an independent, confidential and accessible grievance-redress system dedicated to prisoners with disabilities. Timely registration and disposal of complaints were emphasised as essential features of institutional accountability.
On the educational front, the Bench held that no inmate should be denied access to academic programmes due to disability-related barriers. Prisons have been asked to facilitate distance learning, digital access and open university courses with appropriate accommodations, consistent with judicial precedents affirming the right to education and the broader constitutional vision under Articles 21A and 41.
The Court further clarified that the penalty provisions under Section 89 of the RPwD Act, which punish discrimination and the denial of reasonable accommodation, would apply to prison authorities with necessary modifications. As part of this mandate, all prison personnel and legal-aid lawyers are required to undergo training on their obligations under the RPwD regime.
Another major directive concerns the structured provision of assistive devices. States and Union Territories must prepare detailed plans covering the procurement, maintenance, security protocols and safe usage of assistive technologies such as wheelchairs, prosthetics, hearing aids, white canes, communication devices and other mobility aids.
The Court also held that inmates with benchmark disabilities must receive expanded visitation privileges to maintain family contact and ensure ongoing oversight of their needs, consistent with established constitutional principles governing humane treatment in custody.
All States and Union Territories have been instructed to file comprehensive compliance affidavits within four months, outlining the existing status of accessibility, proposed reforms, procurement processes, capacity-building measures, audit systems and amendments to prison manuals. The matter is scheduled for monitoring on 7 April 2026, with the Court reiterating that disability-inclusive prison governance constitutes a constitutional obligation rather than a matter of administrative discretion.
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