Reasonable Accommodation, Periodical Medical Check-Ups Part of Prisoners' Rights: Madras High Court Directs Biennial Health Audit In Prison

Emphasising that prisoners remain rights-bearing individuals despite incarceration, the Court directed the Superintendent of Central Prison, Palayamkottai, to conduct a master health check-up for all prisoners once every two years and to ensure tailored medical and dietary care for those with specific health conditions.

The Court was hearing a writ petition seeking ordinary leave for her father, a life convict lodged in Central Prison, Palayamkottai, who had recently undergone right-leg amputation due to complications arising from diabetes

The Division Bench comprising Justice G.R. Swaminathan and Justice R. Kalaimathi, while granting 28 days’ ordinary leave to the convict without escort, used the occasion to examine the broader issue of treatment of prisoners with disabilities within the carceral system.

In a strongly worded order, the Bench observed: “In the case on hand, we want to focus our attention on amputee-prisoners. The petitioner's father suffered amputation while in prison as a direct consequence of his diabetic condition. We are of the opinion that if only his condition had been diagnosed well in advance and there had been suitable medical intervention and provision of appropriate diet, such a fate would not have befallen him at all.”

The Bench further reiterated that "reasonable accommodations are not optional but integral to any humane and just carceral system and that a transformation grounded in compassion, accountability and a firm constitutional commitment to dignity and equality is urgently needed".

The Court linked the amputation directly to delayed diagnosis and lack of suitable dietary intervention, signalling institutional responsibility in preventable medical deterioration within prisons.

Referring to the Rights of Persons with Disabilities Act, 2016, the Bench underlined that the statute introduced the concept of “reasonable accommodation” and declared: “A prisoner is also a person. He is entirely in the care, custody and control of the prison authorities. They therefore have to assume the duty to be reasonably accommodating towards the special needs of prisoners with disabilities.”

The Court further clarified that such a duty is enforceable in writ jurisdiction, observing that prisoners with disabilities may demand provision of necessary facilities through judicial proceedings.

Moving beyond the individual case, the Bench held that periodic medical assessment of prisoners is integral to the right to life: “We hold that every prisoner has a right to have a periodical medical check-up which would fall within the scope of Article 21 of the Constitution of India.”

The Court reasoned that only systematic medical screening would reveal conditions such as renal disease or diabetes, enabling tailored diet and treatment. It explicitly directed that the Superintendent of Central Prison, Palayamkottai, conduct a master health check-up for all prisoners once every two years.

Highlighting dietary obligations, the Court stated that jail authorities are obliged to provide food suited to the “unique body condition” of each prisoner. Diabetic inmates, for instance, must be given sugar-free beverages and appropriate medication, including insulin where required.

The Bench placed significant reliance on the Supreme Court’s judgment in L. Muruganantham v. State of Tamil Nadu (2025), which issued comprehensive directions to ensure accessibility, assistive devices, healthcare parity, disability audits, and sensitisation of prison staff. The Court quoted the Supreme Court’s emphasis that reasonable accommodation is integral to a humane carceral system.

It also referred to Sathyan Naravoor v. Union of India (2025), wherein the Supreme Court extended the principles in Muruganantham to all States and Union Territories, mandating independent grievance redressal mechanisms for prisoners with disabilities and structured institutional mechanisms for assistive devices.

The High Court directed immediate enforcement of these Supreme Court directives insofar as they applied to the petitioner’s father

Recognising the particular vulnerability of an amputee prisoner, the Bench issued detailed instructions. It noted that the petitioner’s father may experience “phantom effect” and risk imbalance, and therefore required immediate provision of a cot, a table, and accessible toilet facilities. If an eastern toilet existed, it was to be fitted with a commode.

The Court directed counselling, rehabilitation activities, and periodic medical reviews to prevent ulcers at the amputation site. It also ordered that all required assistive devices, including wheelchairs or crutches, if necessary, be provided immediately.

Since the convict was a senior citizen, the Court directed that he be housed in a block with easy access to toilet and dining facilities and permitted that assistance provided to him by another prisoner could be counted as routine prison work

Acknowledging the rising incidence of diabetes in society at large, the Court presumed a significant prevalence among inmates and directed the Dean, Government Medical College and Hospital, Tirunelveli, to conduct a medical camp in the prison to identify diabetic prisoners requiring intervention.

The Bench cautioned: “Merely because one is a prisoner, one cannot be given a diet that is unsuitable for his body condition. Otherwise, one's condition is bound to deteriorate.”

On the immediate relief sought, the Court directed the grant of twenty-eight days’ ordinary leave without escort to the convict-prisoner, subject to reporting conditions and compliance with the Jail Manual

Cause Title: M. Kalaiselvi v. State of Tamil Nadu & Ors.

Appearances

Petitioner: Advocate S. Mohamed Yunis Raja

Respondents: T.Senthil Kumar, Addl. Public Prosecutor.

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