The rudul sah vs state of bihar case highlights the flaws and inequities present in the Indian penal system through a startling story of wrongful imprisonment. Rudul Sah was detained in 1953 on suspicion of killing his wife, which marked the start of the investigation. On June 3, 1968, the Additional Sessions Judge of Muzaffarpur pronounced him innocent and granted his freedom from custody, marking a pivotal moment in his legal struggle. But Rudul Sah’s horror was far from ended.
rudul sah vs state of bihar Case Facts
- In this case, the man served a longer prison term than required. Rudul Sah, the petitioner, filed a writ based on the habeas corpus petition, which grants one a body, and sought his release from prison.
- The habeas corpus petition was founded on the claim that the petitioner had been kept longer than the allotted term of imprisonment and that the session court had ruled in June 1968 that his detention was unlawful.
- In addition, the petitioner sought collateral redress under article 32 of the indian constitution, the central provision of the Indian constitution that grants its citizens constitutional remedies.
- The petitioner, Rudul Sah, was taken into custody for the murder of his spouse. After serving his term, he was declared innocent by the Sessions Court of Muzaffarpur, Bihar, on June 3, 1968. Nonetheless, in October 1982, he was released from prison following a 14-year sentence.
- In his motion, the petitioner asked the court to address his wrongful imprisonment.
- Furthermore, he asked for the state of Bihar to pay for his medical care. The petition was brought before the court on November 22nd, but he had already been freed from custody.
- But in terms of the further remedy, the court sent the state a show-cause notice.
- On behalf of the state, the jailor prepared an affidavit and presented two documents.
- First, the extra session judge’s ruling, even though the petitioner was found not guilty, mandated that he stay in jail until the Bihar state government sent him another notice.
- Second, at the moment the Sessions Court issued the ruling, it was decided that he could not be prosecuted. Following the medical treatment, a civil surgeon performed a medical examination on the petitioner and found him to be normal. The medical findings were released in October 1982 after being sent in to the law department in February 1977.
rudul sah vs state of bihar Issues
- Whether the Court may award monetary damages under article 32 of the indian constitution for the violation of fundamental rights.
- Whether the right to damages for a violation of one’s right to personal liberty falls inside the purview of article 21 of the indian constitution.
Contentions by the Parties
Petitioner:
- The petitioner argued that despite the court’s verdict of not guilty, he was still had to serve 14 years in prison before being allowed to go. Without his consent, he was imprisoned for a total of 14 years.
- This unlawful detention clearly infringed the petitioner’s fundamental rights to life and liberty, as guaranteed by article 21 of the indian constitution.
- In addition, the petitioner requested reimbursement for any medical expenses related to the therapy that the Bihar State Government had covered. The petitioner also sought unfettered recompense for his rehabilitation as well as damages for this illegal imprisonment.
Respondent:
- The Additional Sessions Judge’s order of authority, which specifically required the state government as well as the inspector general of prisons to approve the petitioner’s release, resulted in the petitioner being detained for an extra 14 years, notwithstanding the court’s decision of acquittal.
- After being declared mentally incompetent at first, the petitioner was eventually declared sound by the legal department and the civil surgeon, who both certified the petitioner’s stability.
rudul sah vs state of bihar Judgment
- Despite Sah’s acquittal, the Supreme Court noted in Rudul Sah v. State of Bihar that his fourteen-year detention was illegal and unfair. The Court emphasized that article 32 of the indian constitution gives the Supreme Court the remedial authority to defend and uphold the basic rights guaranteed by the Indian Constitution. As a result, the Court has the authority to award monetary damages for the violation of fundamental rights.
- The Court emphasized that maintaining the protection of the right to life and personal liberty under article 21 of the indian constitution depends in large part on the right to compensation. Any harmed party whose rights are violated has the right to file a claim for damages. The State is responsible for compensating the victim of a basic rights violation. It would be against the public interest and citizen rights to deny such a right.
- The Court decided that Sah’s protracted incarceration without following the correct legal procedures was illegal, even if he was not of sound mind during the trial. The State’s actions had no basis in truth and were therefore unjustified.
- Given the circumstances, the Supreme Court granted the petition under Article 32 in Rudul Sah v. State of Bihar and directed the Bihar government to provide Sah with Rs. 30,000 in interim compensation, on top of the Rs. 5,000 that he had already received. Within two weeks following the date of the judgment, the compensation was to be paid.
- The Court additionally ruled that Sah might continue to sue the State and its representatives to recover appropriate damages. Sah had the right to pursue damages under tort for false imprisonment because his incarceration was ruled unlawful, which also gave rise to a civil cause of action.
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