Sukanya Shantha

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Factual Background The article “From Segregation to Labour, Manu’s Caste Law Governs the Indian Prison System” was written by journalist Sukanya Shantha (“Petitioner”) and published on December 10, 2020. Discrimination in prisons based on caste was emphasized in the article. Subsequently, the Petitioner challenged the legitimacy of certain clauses of State Prison Manuals before the Supreme Court of India under Article 32 of the Constitution of India. Some of the Prison Manual provisions challenged stated that:(i) A convict sentenced to simple imprisonment shall not be called upon to perform duties of a degrading or menial character unless he belongs to a class or community accustomed to performing such duties;(ii) A convict overseer may be appointed as a night guard provided he does not belong to any class that may have a strong natural tendency to escape, such as men of wandering tribes;(iii) Food shall be cooked and carried to the cells by prisoner-cooks of suitable caste;(iv) Sweepers should be chosen from the Mether or Hari caste, also from the Chandal or other castes, if by the custom of the district they perform similar work when free; and(v) Any prisoner in a jail who is of so high a caste that he cannot eat food cooked by the existing cooks shall be appointed a cook and be made to cook for the full complement of men. The Petitioner argued that caste-based discrimination continues to persist in prisons. The States of Jharkhand, Uttar Pradesh, West Bengal, Maharashtra, Odisha, Karnataka, Andhra Pradesh, and Tamil Nadu appeared before the Supreme Court. Issue Of The Case Whether provisions in the Prison Manuals of various States that distinguish between inmates based on caste are unconstitutional. Whether using vague and indeterminate criteria like “habit,” “custom,” “superior mode of living,” and “natural tendency to escape” as a basis for classifying prisoners serves as a valid differentia or merely acts as a proxy for caste-based discrimination against marginalized communities. Whether prison authorities’ practice of segregating inmates based on caste identity, justified as a measure to prevent conflicts and maintain discipline, is constitutional and compatible with fundamental rights guaranteed under Articles 14, 15, 17, 21, and 23 of the Indian Constitution. Observations The Court ruled that caste-based segregation in jails breaches core constitutional safeguards and continues to discriminate against underprivileged people, even when it is justified under the guise of maintaining discipline. The Court categorically rejected the “separate but equal” theory, concluding that it is incompatible with the Indian Constitution and cannot be utilized to support caste-based prison segregation. The Court observed that prison authorities’ duty to maintain discipline cannot be discharged at the cost of violating fundamental rights and correctional needs of inmates, stating that alternative non-discriminatory measures must be adopted. The Court concluded that definitions of “habit,” “custom,” “superior mode of living,” and “natural tendency to escape” that were used to categorize prisoners were unconstitutionally ambiguous and imprecise, acting only as stand-ins for discrimination based on caste. The Court ruled that, with the exception of certain limited uses to advance equality and social justice, caste-based classification—whether direct or indirect—is prohibited under the Constitution. The Court found that caste-based prisoner classification is arbitrary and unlawful since it lacks any logical connection to the justifiable goals of security, reform, or rehabilitation. The Court pointed out that caste-based isolation will exacerbate caste tensions and hostility rather than address them, undermining the prison system’s rehabilitative goals. Judgment A three-judge Supreme Court bench ruled that the challenged Prison Manual provisions breached Articles 14, 15, 17, 21, and 23. The Court ordered the States to amend their jail manuals within three months. It also asked each state to provide a status report. The court’s decision was written by Chief Justice Chandrachud. Conclusion In addition to ordering extensive reforms in all States and Union Territories and establishing a monitoring system to guarantee compliance and stop prejudice inside the prison system, the Supreme Court ruled that caste-based prison segregation was unconstitutional. Leave a Reply Cancel Reply Logged in as sadalawpublications@gmail.com. Edit your profile. Log out? Required fields are marked * Message* Live Cases Supreme Court of India: Breaking Chains – Ending Caste-Based Discrimination in Prisons Supreme Court of India: Breaking Chains – Ending Caste-Based Discrimination in Prisons sadalawpublications@gmail.com • March 26, 2025 • Live cases • No Comments The Supreme Court rejects the Writ Petition against the Allahabad High Court, holding that grabbing breasts and severing the pyjama string does not amount to an attempt at