Caste-Based Prison Rules Are Overturned by the Supreme Court: A Significant Social Justice Decision

The Supreme Court of India rendered a landmark decision on October 3, 2024, invalidating sections of multiple state prison guidelines that promoted discrimination against people based on their caste. The decision marked a turning point in the struggle for equality, especially for underrepresented groups that have always faced labor divisions based on caste. These laws violate fundamental rights guaranteed by the Indian Constitution by upholding stereotypes from the colonial past and assigning menial labor based on caste.

Chief Justice of India D Y Chandrachud's ruling brought to light the prejudice seen in jail guidelines from Tamil Nadu, West Bengal, Madhya Pradesh, Uttar Pradesh, and Andhra Pradesh. These regulations not only divided prisoners into caste groups but also gave them jail jobs that perpetuated caste divisions.

Historical background: Journalist Sukanya Shantha filed a plea after identifying discriminatory policies in prison manuals from several states. This led to the Supreme Court's ruling. Historically vilified as "criminal tribes" under British colonial rule, Scheduled Castes and denotified tribes were among the disenfranchised communities disproportionately affected by these policies that assigned jail work based on caste.

• For example, convicts belonging to the Scheduled Caste community known as the "Mehtar" caste were required under the Madhya Pradesh Jail Manual (1987) to clean the latrines.
• Similar to this, the 1967 West Bengal Jail Code Rules explicitly divided labor along caste lines by permitting prisoners of "suitable caste" to prepare and deliver meals.

Mandates of the Supreme Court:

The court ruled that all of these discriminatory clauses were illegal in its ruling. Within three months, state administrations and union territories were ordered to update their jail manuals by the verdict. Additionally, the Center was directed to remove caste-based labor divisions from the Model Prison Manual 2016 and the proposed Model Prisons and Correctional Services Act, 2023.

The Criminal Tribes Act and Colonial Legacy:

Prison manuals that contain discriminatory restrictions have their roots in the Criminal Tribes Act of 1871, a colonial law that gave the British authority to designate some communities as "criminal tribes." These groups were labeled as habitual criminals, placed under continual monitoring, and forced to relocate. The stigma attached to these groups persists even after the Act was repealed in 1952, especially for denotified tribes (DNTs).

Even in cases where there have been no past convictions, members of denotified tribes can still be classified by authorities as "habitual criminals" based on arbitrary criteria thanks to prison manuals in states like Madhya Pradesh, the Supreme Court said. The court emphasized how these clauses infringe these communities' fundamental rights and reinforce colonial stereotypes.

Unnotified Tribes and Penal Work:

Tribes that have been denotified, who have traditionally been referred to as "criminal tribes," nonetheless experience prejudice in both society and prisons. Members of denotified tribes could be treated like habitual criminals under the Madhya Pradesh manual, so associating their ethnicity with criminality. Similar laws were in place in Tamil Nadu, Kerala, and Andhra Pradesh, allowing convicts to be classified as habitual criminals even in the absence of a criminal record based on their caste and prior behaviour. The ruling emphasizes how important it is to end these backwards practices.

Constitutional Infractions

The ruling of the Supreme Court found several constitutional rights to have been violated, especially with reference to Articles 14, 15, 17, 21, and 23. These infractions and the ruling's wider ramifications are explained in the section that follows.

Equal Rights (Article 14)

The court declared that classifying prisoners according to their caste is illegal. The Supreme Court highlighted that caste cannot be used as a basis for classification unless it benefits those who have been the victims of discrimination based on caste. Article 14 ensures equality before the law. Caste-based prison labor assignments deny inmates the chance to change and strengthen social divides.

Crucial Landmark Decisions:

Indra Sawhney v. Union of India (1992): The court deliberated on the necessity of equality and affirmative action measures.
In the 2017 case K.S. Puttaswamy v. Union of India, the reach of Article 14 was expanded to guarantee equality in developing situations.

Article 15: Right Against Discrimination

Discrimination on the grounds of caste, religion, ethnicity, or gender is forbidden by Article 15. The court determined that the prison manuals' assignment of sweeping and cleaning duties to inmates from lower castes was a form of discrimination against marginalized people. This violates Article 15 by sustaining the myth that members of particular castes are exclusively suitable for manual labor.

Article 17: Abolition of Untouchability

The court noted that untouchability, which is prohibited by Article 17, was clearly practiced under some jail regulations. For example, in Uttar Pradesh, prisoners belonging to lower castes were given menial tasks like cleaning latrines. This technique perpetuates untouchability in a contemporary setting and upholds caste-based labor divisions.

Legislative Source:

The Protection of Civil Rights Act of 1955 was passed in order to guarantee that untouchability would never exist again.

Article 21: The Right to Life with Dignity

The right to life and personal liberty, which includes the right to a dignified existence, are protected by Article 21. According to the court, giving marginalized convicts menial work robs them of their dignity and hinders their ability to change. Prior to now, the Supreme Court has interpreted Article 21 to cover rights to privacy, dignity, and an inclusive society.

Crucial Landmark Decisions:

Maneka Gandhi v. Union of India (1978): The right to live in dignity is protected by Article 21.
Fairness K.S. Puttaswamy vs. Union of India (2017): expanded on how the right to life should be interpreted.

Article 23: Prohibition of Forced Labor

The court determined that it is unlawful for upper-caste inmates to engage in more "honourable" work while forcing underprivileged inmates to perform menial labor—a practice that is outlawed by Article 23. Exploiting social and economic vulnerabilities can also lead to forced labor; it's not necessarily about physical coercion.

Comparative Study of Other Nations' Prison Reforms:

In order to contextualize India's prison reforms, it is important to look at other nations' approaches to prison labor and discrimination:

• United States: Prison discrimination based on race and ethnicity has been a major problem, particularly with regard to prison labor. The 13th Amendment's provision allowing for involuntary slavery as a form of punishment for criminal activity has drawn criticism due to its unequal effect on African Americans.
• United Nations: With an emphasis on rehabilitation and dignity, the UN Standard Minimum Rules for the Treatment of Prisoners, often known as the Nelson Mandela Rules, place a strong emphasis on treating inmates fairly and without discrimination.

Prison Reforms and Restorative Justice in India:

The larger idea of reformative justice, which aims to rehabilitate rather than just punish inmates, is also reflected in the Supreme Court's decision. The ruling opens the door for systemic adjustments to India's penal system:

2016 Model Prison Manual: Emphasizes skill development, vocational training, and rehabilitation for inmates.
Model Correctional Services and Prisons Act of 2023: Anticipated to tackle the necessity of jail modifications and the fair allocation of prison labor, guaranteeing that no community experiences prejudice based on caste.

In summary:

The ruling by the Supreme Court is a big step in the right direction towards eliminating the last vestiges of caste-based prejudice in India's jail system. By maintaining the equality, dignity, and nondiscrimination guaranteed by the constitution, the court has demonstrated its continued dedication to social justice. This decision is a potent reminder that structural change is necessary to eradicate past disparities in all state institutions, including prisons.