Punjab & Haryana High Court, Chandigarh
CitationAIR 1980 SC 1535, (1980) 3 SCC 526
CourtSupreme Court of India
Date29 April 1980
Year1980
BenchV.R. Krishna Iyer, R.S. Pathak, O. Chinnappa Reddy JJ.
Acts/ArticlesArticle 14, Article 21
CategoryConstitutional 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.

Brief Facts

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.

Ratio Decidendi

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.

Impact & Significance

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.

Tags & Related Topics

Constitutional Law Criminal Law Article 14 Article 21
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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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