A) Abstract/Headnote
The Supreme Court’s judgment in Sukanya Shantha v. Union of India & Ors. ([2024] 10 S.C.R. 493) examined caste-based discrimination in Indian prisons, focusing on the constitutionality of provisions in State Prison Manuals that perpetuate this practice. The petitioner argued that such provisions violate Articles 14, 15, 17, 21, and 23 of the Constitution. The judgment directs all States and Union Territories to revise their prison manuals, aligning them with constitutional mandates of equality, dignity, and non-discrimination. It holds that practices such as assigning caste-based labor and maintaining caste-based records in prisons are unconstitutional. Further, it mandates the deletion of discriminatory references to “habitual offenders,” ensuring they adhere to specific legal definitions. The decision also highlights the importance of the Model Prison Manual 2016 and the Model Prisons and Correctional Services Act, 2023, while pointing out their inadequacies regarding caste-based segregation. The judgment underscores the fundamental role of constitutional values in ensuring equal treatment of marginalized communities within the penal system.
Keywords
Caste-based discrimination, prison manuals, Articles 14, 15, 17, 21, and 23, habitual offenders, prison reforms.
B) Case Details
- Judgment Cause Title: Sukanya Shantha v. Union of India & Ors.
- Case Number: Writ Petition (C) No. 1404 of 2023
- Judgment Date: October 3, 2024
- Court: Supreme Court of India
- Quorum: Dr. Dhananjaya Y Chandrachud, CJI, J.B. Pardiwala, and Manoj Misra, JJ.
- Author: Dr. Dhananjaya Y Chandrachud, CJI
- Citation: [2024] 10 S.C.R. 493
- Legal Provisions Involved: Articles 14, 15, 17, 21, and 23 of the Constitution; Model Prison Manual, 2016; Model Prisons and Correctional Services Act, 2023.
- Judgments Overruled: None explicitly mentioned.
- Law Subjects: Constitutional law, human rights law, prison reforms, and anti-discrimination law.
C) Introduction and Background of the Judgment
The judgment arose from a writ petition filed by journalist Sukanya Shantha under Article 32 of the Constitution. It targeted caste-based discriminatory practices entrenched in various State Prison Manuals. The petition highlighted practices including manual labor assignments based on caste, segregation of barracks, and labeling denotified tribes as “habitual offenders.” These practices contravene constitutional provisions guaranteeing equality, non-discrimination, and dignity.
The case gained momentum following an article by the petitioner exposing these practices and sought to reform State Prison Manuals and the Model Prison Manual, 2016, to eliminate discriminatory provisions. The judgment reflects the evolving constitutional vision of substantive equality and social justice.
D) Facts of the Case
- The petitioner exposed systemic caste-based discrimination in Indian prisons, particularly in assigning labor tasks and maintaining prisoner records.
- State Prison Manuals permitted segregation based on caste and assigned specific tasks such as cleaning and sweeping to marginalized communities, perpetuating untouchability.
- Provisions defined “habitual offenders” in a manner that targeted denotified tribes, reinforcing colonial stereotypes.
- The Model Prison Manual 2016 inadequately addressed caste discrimination.
- The petitioner sought the removal of discriminatory practices, deletion of caste references in prison records, and redefinition of “habitual offenders.”
E) Legal Issues Raised
- Whether the caste-based provisions in State Prison Manuals violate Articles 14, 15, 17, 21, and 23.
- Whether the concept of “habitual offenders” as defined targets denotified tribes and violates constitutional equality.
- Whether segregation of prisoners and caste-based labor divisions constitute untouchability under Article 17.
- Whether the provisions violate the right to dignity under Article 21.
F) Petitioner’s Arguments
- Violation of Fundamental Rights: Provisions in the prison manuals contravene Articles 14, 15, 17, 21, and 23 by sanctioning caste-based practices.
- Colonial Stereotypes: The classification of “habitual offenders” stems from colonial laws like the Criminal Tribes Act and unjustly targets denotified tribes.
- Model Prison Manual Deficiencies: The Model Prison Manual 2016 does not adequately address caste-based labor assignments or caste segregation.
- Constitutional Obligation: State Prison Manuals must align with constitutional mandates to abolish untouchability and promote equality.
G) Respondent’s Arguments
- State Domain: Prisons fall under State jurisdiction (Entry 4, List II, Seventh Schedule).
- Existing Measures: The Union government referred to advisories issued to States prohibiting caste-based discrimination in prisons.
- Progressive Reforms: States like West Bengal argued that discriminatory practices had been abolished, with amendments proposed to remove outdated rules.
- Definition of Habitual Offenders: Respondents emphasized the need for clarity and adherence to State legislation.
H) Related Legal Provisions
- Article 14: Ensures equality before the law.
- Article 15: Prohibits discrimination based on caste.
- Article 17: Abolishes untouchability.
- Article 21: Guarantees the right to life with dignity.
- Article 23: Prohibits forced labor and human trafficking.
I) Judgment
a. Ratio Decidendi
- Provisions perpetuating caste-based labor and segregation violate Articles 14, 15, 17, 21, and 23.
- Caste cannot be used as a principle of classification unless it promotes equality and social justice.
- Definitions of “habitual offenders” targeting marginalized communities are unconstitutional.
b. Obiter Dicta
- Institutional discrimination in prisons mirrors societal biases and must be eradicated.
- Legal Service Authorities play a critical role in monitoring compliance with constitutional safeguards.
c. Guidelines
- All States/UTs to revise prison manuals to eliminate caste-based discrimination.
- Delete caste references in prisoner registers.
- Adhere to constitutional definitions of “habitual offenders.”
- File compliance reports to ensure the implementation of these directions.
J) Conclusion & Comments
The judgment is a milestone in addressing caste-based institutional discrimination. It aligns with the constitutional vision of substantive equality and social justice, addressing long-standing injustices within the penal system.
References
- Constitution of India
- Model Prison Manual, 2016
- Unni Krishnan v. State of Andhra Pradesh (1993) 1 SCC 645
- Maneka Gandhi v. Union of India (1978) 2 SCR 621
- Criminal Tribes Act and related repeals
