किशोर सिंह बनाम राजस्थान राज्य
| Citation | AIR 1981 SC 625 |
| Court | Supreme Court of India |
| Date | 4 November 1980 |
| Year | 1981 |
| Bench | V.R. Krishna Iyer, R.S. Pathak JJ. |
| Acts/Articles | Article 21, Article 14 |
| Category | Constitutional 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.
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.
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.
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.
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Read AnalysisThis 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).
22+ years of practice before Punjab & Haryana High Court and Supreme Court of India.