Punjab & Haryana High Court, Chandigarh
CitationAIR 1981 SC 625
CourtSupreme Court of India
Date4 November 1980
Year1981
BenchV.R. Krishna Iyer, R.S. Pathak JJ.
Acts/ArticlesArticle 21, Article 14
CategoryConstitutional Law, Criminal Law

Key Principle Established

Solitary confinement and use of iron fetters on prisoners is inhuman and violates Article 21. To be resorted to only in the rarest of rare cases.

Brief Facts

Prisoners in Jaipur Central Jail sent a telegram to the Supreme Court complaining of illegal solitary confinement punctuated by iron fetters for over eight months. Justice Krishna Iyer immediately ordered their release from solitary confinement.

Ratio Decidendi

The Court held that solitary confinement and iron fetters are barbaric and violate Article 21. Even convicted prisoners retain their fundamental rights — imprisonment does not strip a person of all human dignity. Solitary confinement may be resorted to only in the rarest of rare cases with proper judicial authorization.

Impact & Significance

This judgment, building on Sunil Batra (1978), established the rights of prisoners as part of Article 21 jurisprudence. It reinforced that “an iron curtain” must not divide constitutional rights from prison practices, and that courts will act swiftly to protect prisoners from inhuman treatment.

Tags & Related Topics

Constitutional Law Criminal Law Article 21 Article 14
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Disclaimer

This judgment summary is for educational and research purposes. While care has been taken to accurately represent the ratio and findings, for authoritative reference always consult the original judgment text from official sources (SCC Online, AIR, Manupatra, or court websites).

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