The recent Supreme Court decision in Sukanya Shantha v. Union of India (2024) has become a significant milestone in addressing the issue of discrimination within Indian prisons. At the core of this case was the caste-based segregation in prison labour, which the Court ruled unconstitutional. The judgment struck down provisions within jail manuals that assigned work to prisoners based on their caste, as this practice was found to perpetuate caste discrimination and violate the fundamental rights of prisoners as guaranteed under the Indian Constitution.
Historically, Indian courts have frequently addressed cases where prison rules imposed arbitrary classifications among inmates, resulting in unequal treatment. The principle that no prisoner should face arbitrary segregation has been reinforced in various judgments over the years. The Court’s rationale in such cases has often been that discrimination based on irrational or prohibited grounds—such as caste, economic status, or social background—cannot withstand the scrutiny of constitutional principles under Articles 14 and 15, which guarantee equality and non-discrimination.
One of the earlier cases that tackled such issues was Prem Shankar Shukla v. Delhi Administration (1980).[1] In this case, the Supreme Court examined a provision under the Punjab Police Rules, which differentiated between under-trial prisoners, classifying them as either “better class” or “ordinary.” Only those classified as “better class” were exempted from wearing handcuffs, while others were not. The Court found this policy irrational, holding that social or economic status should not influence whether a prisoner was handcuffed. The Court emphasized that classifying prisoners on arbitrary criteria like financial standing was unjustified, as it implied that poorer prisoners posed a greater danger to society, which was an unreasonable assumption. Consequently, the provisions were declared unconstitutional.
In another landmark case, Inacio Manuel Miranda v. State (1988).[2]the Bombay High Court addressed discrimination in prison regulations regarding prisoners’ rights to write letters. Under the Goa, Daman, and Diu Prisoners Rules, inmates were segregated into categories— “Class-I” and “Class-II”—with different limitations on the number of letters each class could write monthly. Class-I prisoners were allowed to write four letters per month, while Class-II prisoners could only send two. The Court ruled this restriction discriminatory, arguing that it unfairly impinged on prisoners’ freedom of expression. The Court’s decision built upon its earlier ruling in Madhukar Bhagwan Jambhale v. State of Maharashtra (1984),[3] where it struck down a rule preventing prisoners from writing letters to co-prisoners, finding it arbitrary and lacking any logical basis. The judgments in these cases emphasized that a prisoner’s rights to equal treatment and expression should not be curtailed by arbitrary classification systems.
The Supreme Court’s ruling in Sukanya Shantha v. Union of India (2024) involved a particularly stark example of caste-based discrimination within prisons. In this case, the Court reviewed certain state prison rules that classified inmates according to their caste background for labour assignments. Specifically, prisoners from marginalized castes were designated for cleaning and other menial jobs, while prisoners from other castes were assigned more desirable roles like cooking. The justification given was that certain castes were “accustomed” to performing certain tasks. The Court, however, found this reasoning to be discriminatory and unconstitutional, as it assigned work based on caste rather than individual ability or qualifications, undermining any potential for prisoner reformation. The judgment ordered the state to eliminate such caste-based labour classifications and implement reforms that would allow equal opportunities for all prisoners.
In a related case that highlighted issues around classification, the Calcutta High Court in Gaur Narayan Chakraborty and Others (2012). dealt with a claim regarding the treatment of Maoist prisoners. The petitioners argued that Maoist prisoners, who were charged under the Unlawful Activities (Prevention) Act, should be classified as political prisoners. This classification would entitle them to certain privileges under the West Bengal Correctional Services (WBCS) Act, 1992. The trial court initially rejected this claim, viewing the Maoist activities as acts of terrorism rather than political opposition. However, the Calcutta High Court later ruled that political prisoners are not solely defined by the legality of their actions but by their involvement in movements that pursue ideological objectives, even if these movements are unlawful. The High Court’s judgment did not find Favor in the Supreme Court due to procedural issues, but it underscored the idea that all prisoners, regardless of their offenses, deserve to be treated with dignity.
The Calcutta High Court also observed that prisoners classified as political were entitled to certain basic amenities, such as a chair, table, light, and mattress, and even privileges like access to writing materials, newspapers, and books sent by relatives. The Court suggested that these amenities should ideally be provided to all prisoners, not just those classified as political. It recommended that the state should consider extending these basic human rights across prison populations to enhance the dignity of all inmates. Such changes would mark an improvement in living conditions within prisons and help erode the distinctions that restrict fair treatment.
The ruling in Sukanya Shantha v. Union of India reflects a broader judicial commitment to ensuring non-discriminatory and dignified treatment within prisons. The Supreme Court’s directive to eliminate caste-based segregation in prison labour is a crucial step toward dismantling discriminatory structures in the prison system. However, many advocates and reformers believe that this is only one part of a much larger issue. In addition to eradicating discriminatory practices, they argue that incorporating fundamental amenities and rethinking the overall structure of prison classifications are necessary reforms to ensure a dignified life for all prisoners.
To further these goals, the Model Prison Manual of 2016 could be amended to include a provision that guarantees all prisoners certain basic rights, such as access to hygiene, food, exercise, and communication with family. These rights, if granted universally, would not only help reduce discrimination but would also affirm the humanity of inmates, promoting rehabilitation over mere punishment. Implementing such reforms would align the prison system more closely with the Constitution’s principles of equality and non-discrimination, providing a minimum standard of humane treatment to all prisoners irrespective of caste, class, or political beliefs.
By addressing these broader issues, the judicial system is gradually moving toward a prison system that respects basic human dignity for all prisoners. The Sukanya Shantha case has sparked essential conversations about the intersection of caste, rights, and penal reform in India. Following the Court’s direction to eliminate caste-based classifications, state governments are now encouraged to review their prison policies and ensure that prisons function as institutions of rehabilitation, not as extensions of caste or class discrimination.
The Sukanya Shantha ruling, however, brought to light one of the most entrenched and stark forms of discrimination: caste-based segregation within prisons. In this case, the Supreme Court examined a practice where prisoners from marginalized castes were assigned menial tasks like cleaning, while prisoners from other castes were assigned more desirable roles like cooking. This classification, the state argued, reflected traditional caste roles, yet the Court found it discriminatory, as it was based on caste rather than individual qualifications. The judgment concluded that such practices perpetuated caste identities and denied equal opportunities for reformation. The Supreme Court ordered the states to eliminate caste-based labour classifications and implement reforms that would ensure fair treatment of all inmates, regardless of caste.
In a related case, Gaur Narayan Chakraborty and Others (2012), the Calcutta High Court examined whether prisoners affiliated with Maoist organizations could be classified as political prisoners, which would entitle them to certain privileges under the West Bengal Correctional Services (WBCS) Act, 1992. Although the trial court had previously rejected this demand, the High Court found that political prisoners are not defined solely by the legality of their actions but also by their ideological objectives, even if those activities are unlawful. While the Supreme Court ultimately did not rule on this decision, the Calcutta High Court’s judgment emphasized the importance of treating prisoners with dignity regardless of the nature of their offences.
In the Chakraborty case, the High Court also observed that prisoners classified as political were entitled to various amenities, such as access to a chair, table, mattress, pillow, and other comforts. They could also receive newspapers, books from family, and writing materials. The Court suggested that these basic amenities should not be restricted to political prisoners but should be extended to all prisoners to promote human dignity within prison walls. The High Court argued that enhancing the living conditions of prisoners through these basic amenities would help erode class distinctions and bring fairness to the prison environment.
The Supreme Court’s ruling in Sukanya Shantha reaffirms the principle that discrimination based on caste or class within prisons is unconstitutional and incompatible with basic human dignity. The decision sets a critical precedent by eliminating caste-based classifications in prison labour and calls for states to review and reform prison policies to prevent similar discrimination. Legal experts, reform advocates, and civil rights groups view this judgment as a significant move towards dismantling the systemic discrimination that has long pervaded India’s prison systems.
Implementing this judgment’s directives requires changes beyond ending caste-based assignments. Reformers argue for integrating fundamental rights and dignified living conditions into the prison system. To achieve this, the Model Prison Manual of 2016 could be amended to guarantee basic amenities—such as adequate hygiene, nutrition, and access to communication with family—to all prisoners. Such universal standards would reduce the discriminatory practices that have historically compromised the dignity of inmates and would affirm their basic human rights. By ensuring all prisoners are treated fairly, irrespective of their caste, class, or political affiliation, these reforms would align the prison system more closely with constitutional principles of equality and non-discrimination.
These broader changes are essential to build a prison system that respects prisoners’ dignity and promotes their rehabilitation. The Sukanya Shantha decision has sparked an important conversation about the intersection of caste, rights, and penal reform in India. State governments are now encouraged to act upon this judgment, ensuring that prisons serve as spaces for genuine reform and not as institutions that perpetuate discrimination and inequality.
[1] Prem Shankar Shukla v. Delhi Administration, MANU / SC / 0084 / 1980.
[2] Inacio Manuel Miranda v. State, MANU / MH / 0042 / 1984.
[3] Madhukar Bhagwan Jambhale v. State of Maharashtra, MANU/MH/0042/1984.
Author: Aditya Kumar, a 2nd year, B.B.A.LL.B( Hons.) student at Chanakya National Law University, Patna.
