प्रेम शंकर शुक्ला बनाम दिल्ली प्रशासन
| Citation | AIR 1980 SC 1535, (1980) 3 SCC 526 |
| Court | Supreme Court of India |
| Date | 29 April 1980 |
| Year | 1980 |
| Bench | V.R. Krishna Iyer, R.S. Pathak, O. Chinnappa Reddy JJ. |
| Acts/Articles | Article 14, Article 21 |
| Category | Constitutional Law, Criminal Law |
Key Principle Established
Handcuffing of prisoners is prima facie inhuman and unconstitutional under Article 21 except in extreme circumstances with recorded reasons.
A prisoner in Tihar Jail sent a telegram to the Supreme Court complaining that handcuffs were being forced on him despite the Court’s earlier directions in Sunil Batra.
Justice Krishna Iyer held that handcuffing is prima facie inhuman and unreasonable, violating Article 21. It may only be resorted to in rare cases where the prisoner is violent or likely to escape, and the reasons must be recorded in writing.
This judgment, along with Sunil Batra and Kishore Singh, created the prisoners’ rights framework under Article 21. The guidelines on handcuffing are now standard practice in all courts.
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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.