Rudul Sah vs. State of Bihar

The Court, acknowledging the complexity of questions arising and the requirement of consideration in greater detail passed the following:

Unlawful Detention

The Court unanimously declared the petitioner’s incarceration for over 14 years even after his acquittal to be wholly unjustified and deemed it to be violative of his right to liberty enshrined in Article 21 of the Indian Constitution. The Court did not find any merit in the State’s argument that was declared to be of unsound mind at the time of acquittal. The Court states that there was no medical evidence proving the same and that if this had been the case, the procedural irregularities would have prevented him from standing the trial.

Criticizing State Authorities

The Court condemned the respondent for its conduct, especially the behavior of the prison administration. The Court disapproved of the behavior of the State for violating the fundamental rights of the petitioner and deemed the actions of the State as negligent and callous. 

Article 21

The Court states that the right to life and personal liberty guaranteed to an individual under Article 21 of the Indian Constitution is of supreme importance and no one has the authority to deny it in an arbitrary manner. Further, the Court stated that just by ordering release of a prisoner who was unlawfully detained doesn’t mean that he has not been deprived of his basic constitutional freedom. The Court further emphasized that monetary compensation is of huge significance in providing Justice to the petitioner for the violation of his fundamental right.

Article 32

The Court stated that under Article 32 of the Indian Constitution, it mainly had the power to grant remedies in cases where the fundamental rights have been violated. However, the Court emphasized that it had the powers to grant compensation, more so when there was an egregious violation of the fundamental rights of an individual under Article 21 of the Indian Constitution. The Court stated that this was paramount considering the spirit of Article 21 that is required to be preserved.  

Compensation

The Supreme Court awards a compensation worth Rs. 35,000 to the petitioner for his illegal detention. Out of this sum, Rs.5000 was paid by the State and the balance sum was to be paid within 14 days. The Court asserted that the act of awarding compensation to the petitioner was an interim measure and that this did not in any manner restricted the right of the petitioner from further damages. The petitioner could do so by filing a fresh lawsuit against the respondent and concerned officials. 

Systemic Reform

While this was a stand alone case concerning a single individual who was wrongfully detained, the Court delved deeper into the existing gaps in the criminal justice system of India, specifically the administration of prison. The Court encouraged the High Court of Patna to look into similar matters and investigate any such illegal detentions of individuals within the Jails of Bihar. The Court urged the High Court of Patna further to gather details in instances where a prisoner was imprisoned beyond his term of sentencing. Moreover, the Court advised the top-ranking officials to resolve the underlying issues that prevailed in the prison system of the respondent.

Conclusion

This case has played a significant role in the aspects of state liability and constitutional Jurisprudence. While the act of awarding compensation wasn’t something any of the Courts had done prior to this Judgement, this case went a step ahead and set a precedent of progressive Judgments by the courts where they contemplated the broader perspective of their actions and ventured into Judicial activism. By upholding the spirit of the Article 21 of the Indian Constitution, the Supreme Court set a benchmark for providing compensation and relief in the matters where the fundamental right or rights of an individual is violated.  

The commencement of compensatory Jurisprudence in the Constitutional law has changed the fate of uncountable individuals who were left at the mercy of the courts to seek Justice but did not get any monetary relief unless they filed a fresh lawsuit against the same. Now, the aggrieved individuals who suffered immensely, sometimes for years, could demand compensation and the same could be granted by the Apex Court by exercising the powers bestowed upon it under Article 32 of the Indian Constitution.

This case not only brought to light the right of the aggrieved parties to seek compensation when their fundamental rights have been infringed but also the State of misery they have to undergo when their basic fundamental rights are violated. Moreover, this case proved paramount in spotlighting the appalling conditions of the detainees in the Criminal Justice system of India. It highlighted their plight where even a Court’s Judgement cannot save them from imprisonment for extended time.