The case of prem shankar shukla v delhi administration stands as a testament to human dignity in the furnace of the Indian legal system. In a 1980 decision that went deeply into the spirit of justice, the Supreme Court called into question the custom of handcuffing defendants who are awaiting trial.
This case study examines the Court’s declaration that the presumption of innocent is a fundamental component of human rights rather than merely a legal formality, illustrating the interdependence of our social structure as stated by King. It emphasizes the Court’s position that compassion for the least fortunate among us, rather than the treatment of a country’s elite, is a better indicator of that country’s commitment to justice.
prem shankar shukla v delhi administration Case Facts
- In this particular case, while being transported from jail to the magistrate’s court and back, the petitioner, who was an undertrial prisoner at the time,sent a telegraph to the Supreme Court.
- The petitioner’s allegation about the regular application of handcuffs while he was being transported from Tihar Jail to Delhi courts for trial is at the center of this case.
- The petitioner, a prisoner awaiting trial, objected to the cruel and painful custom of being shackled in public even though earlier court rulings prohibited it.
- The petitioner, a prisoner classified as belonging to a “better class”, argued that his social standing, upbringing, and educational background should free him from shackles.
- Although the prisoner’s petition was denied, the High Court issued a directive prohibiting the use of handcuffs unless necessary in certain situations.
- It stated that regular Indian undertrials will always be handcuffed while being transported between the jail and the court, while better class inmates will only be handcuffed if they are deemed to be dangerous or in need of rescue.
- But despite police orders, the petitioner was handcuffed multiple times, which prompted a habeas corpus petition.
- In his complaint, the petitioner brought up constitutional concerns about individual freedom, human dignity, and how inmates are treated in accordance with Articles 14, 19, and 21 of the Constitution.
- The legal discussion examined whether handcuffing qualifies as cruel, inhuman, or degrading treatment, delving into the tension between security considerations and human rights.
- The State used the petitioner’s security risks as justification for the validity of handcuffing under applicable laws and regulations.
prem shankar shukla v delhi administration Issues
- Was it appropriate or inappropriate to handcuffing a prisoner?
- Was the punjab police rules 1934’s classification of inmates into the regular and superior classes justified?
Contentions by the Parties
Petitioner:
- When someone is arrested, they do not lose their fundamental rights. Even when incarcerated, it keeps the individual safe. As a result, the petitioner emphasized that the way in which prisoners awaiting trial are treated needs to be at odds with these constitutional guarantees.
- The petitioner also contested the punjab police rules 1934’s categorization of convicts into “ordinary and better” classes, arguing that it violated article 14 of the indian constitution, and that there was no evidence connecting the classification to the goal the law was intended to accomplish. Additionally, it violates international human rights norms and human dignity.
Respondent:
- The respondent’s attorneys contended that the handcuffing procedure followed the guidelines outlined in the Police Act. Beyond the courtroom, nothing was done, and according to the Police Act, officers have the authority to handcuff anyone they believe to be a suspect as a precautionary step.
- The Respondent further contended that if given the chance, any prisoner may escape at any time. The society will start to fear this. As a result, as a security precaution, handcuffing a prisoner or any suspect is required. In this case, no rights are being infringed. The respondent contended that the petitioner was transported from prison to the courtroom while being guarded by a dedicated police unit. Therefore, handcuffing the prisoner seems sense.
prem shankar shukla v delhi administration Judgment
- The Punjab Prisoners (Attendance in Courts) Rules, 19697, Section 11(2), specify how prisoners are classified according to their caste and family history. article 14 of the indian constitution, which guarantees equality before the law, is fully broken by this regulation. A prisoner cannot be treated unfairly because of their caste or family history.
- Basic human rights will be violated if an innocent person who has not been found guilty by the court is handcuffed; yet, the court has also stressed the need for security measures. In addition to having an arrest warrant, the police should notify the subject of the arrest of the reasons for it.
- If the authorities believe there is a clear risk that the prisoner will break the law, they will deploy handcuffs.
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