Constitution of India — Articles 14, 15, 21 — Prison administration — Right to life and dignity of prisoners — Rehabilitative justice — Open Correctional Institutions (OCIs) as constitutional instruments of reform. (Paras 33–42, 74–76)
This Court reaffirmed that incarceration does not extinguish fundamental rights and that Article 21 guarantees prisoners the right to live with dignity, including access to reformative and rehabilitative avenues. Open Correctional Institutions, premised on graded liberty, trust and self-discipline, are constitutionally aligned mechanisms for decongestion, reformation and reintegration.
Ratio Decidendi: The constitutional guarantee of dignity under Article 21 obliges the State to operationalise reformative penology through effective establishment, expansion and humane governance of Open Correctional Institutions; prison administration must be rehabilitation-oriented and equality-compliant.
Prison Overcrowding — Under-utilisation of Open Correctional Institutions — Duty of States and Union Territories — Judicial enforcement of reformative framework. (Paras 45–48, 73–74)
Despite prior directions in In Re: Inhuman Conditions in 1382 Prisons, existing OCIs remained substantially under-utilised and several States/UTs lacked such facilities altogether. The Court held that failure to utilise or establish OCIs defeats both reformative objectives and constitutional mandates. States/UTs were directed to assess feasibility, frame time-bound protocols, fill vacancies, and expand infrastructure.
Ratio Decidendi: Where empirical material demonstrates chronic overcrowding and simultaneous under-utilisation of OCIs, States are constitutionally obligated to establish, expand and optimally utilise open correctional infrastructure through structured, time-bound measures.
Gender Equality in Prison Administration — Exclusion of women from OCIs — Violation of Articles 14, 15 and 21 — Mandate for gender-sensitive inclusion. (Paras 49–54, 110–112)
Several States excluded women prisoners from eligibility for OCIs or failed to operationalise transfer despite legal permissibility. Relying upon constitutional equality guarantees and international norms (Nelson Mandela Rules; Bangkok Rules), the Court held such exclusion to be impermissible. States were directed to restructure capacity, amend rules, and ensure timely transfer of eligible women prisoners.
Ratio Decidendi: Denial or exclusion of women prisoners from access to Open Correctional Institutions constitutes gender discrimination violative of Articles 14 and 15(1) and infringes the right to dignity under Article 21; States must ensure gender-sensitive and non-discriminatory access.
Eligibility Criteria — Rigid incarceration thresholds — Need for individualised reformative assessment — Prohibition against labour-camp model. (Paras 55–61, 113–117)
Stringent requirements of 4–21 years of prior incarceration and agriculture-centric functioning diluted the reformative character of OCIs. The Court mandated rationalisation of eligibility criteria based on reformative potential and institutional conduct, diversification of vocational training, fair wages, healthcare, banking access, education, grievance redressal and family integration.
Ratio Decidendi: Eligibility for transfer to OCIs must be based on individualised reformative assessment rather than rigid temporal thresholds; OCIs must function as structured rehabilitation centres and not as custodial labour camps.
Uniform Standards — Fragmented governance across States — Constitution of High-Powered Committee for Common Minimum Standards. (Paras 62–65, 118–126)
Noting disparities in eligibility norms, wages, healthcare, family integration and discipline, the Court directed constitution of a High-Powered Committee headed by a former Judge of this Court to formulate Common Minimum Standards for governance of OCIs, harmonise practices, and recommend systemic reforms.
Ratio Decidendi: To secure equality and uniform constitutional compliance in prison administration, nationally consistent Common Minimum Standards for Open Correctional Institutions are necessary and may be judicially mandated through expert institutional mechanisms.
Cost-Effectiveness of OCIs — Fiscal prudence and administrative sustainability — Expansion mandated. (Paras 66–72, 127–129)
Empirical data from Rajasthan demonstrated stark cost differentials: per-prisoner per-day expenditure of approximately Rs.333.12 in closed prisons versus Rs.49.60 in open prisons. Open prisons required minimal staffing and infrastructure, with inmates largely self-sustaining. The Court held that expansion of OCIs advances both constitutional and fiscal rationality.
Ratio Decidendi: Open Correctional Institutions are demonstrably more cost-effective and administratively sustainable than closed prisons; expansion of open correctional infrastructure is constitutionally justified and fiscally prudent.
Continuing Mandamus — Monitoring by High Courts — Institutional accountability. (Paras 129–133)
To ensure effective implementation, High Courts were directed to register suo motu writ petitions as continuing mandamus; State-level Monitoring Committees were mandated; and periodic reporting mechanisms were instituted.
Ratio Decidendi: Where structural reform of prison administration is required to enforce fundamental rights, this Court may invoke continuing mandamus and multi-tiered monitoring to secure effective compliance.
Operative Outcome
Comprehensive directions issued for:
• Establishment and optimal utilisation of OCIs;
• Inclusion of women prisoners;
• Rationalisation of eligibility norms;
• Strengthening of rehabilitative frameworks;
• Constitution of a High-Powered Committee for Common Minimum Standards;
• Expansion of open correctional infrastructure; and
• Judicial monitoring through High Courts and State Committees.
Matter listed for periodic compliance review.
