Supreme Court Directs Centre To Frame Model Guidelines For Nationwide Uniform Reforms in Beggars’ Homes
The Court held that the failure to secure humane living conditions in such institutions amounts to a constitutional breach of the fundamental right to life with dignity.
Justice J.B. Pardiwala, Justice R. Mahadevan, Supreme Court
The Supreme Court has directed the Centre to frame and notify model guidelines within three months to ensure that reforms in Beggars’ Homes are uniformly implemented across all States and Union Territories.
The Court was hearing a PIL concerning the conditions of Beggars’ Homes, which began with reports of deaths following a cholera outbreak at the Lampur Beggars’ Home in Delhi in 2000.
A Bench comprising Justice J.B. Pardiwala and Justice R. Mahadevan, while adjudicating the matter, observed that, “Beggars’ Homes require a paradigm shift – from being perceived as instruments of social control to being recognised as spaces of social justice. The failure to ensure humane conditions in such Homes does not merely amount to maladministration; it constitutes a constitutional breach of the fundamental right to life with dignity.”
Senior Advocate Ranjit Kumar assisted the Court as Amicus Curiae.
Background
The case arose after a cholera outbreak in the Lampur Beggars’ Home in Delhi in May 2000, which resulted in multiple deaths and serious illness among inmates. Allegations were made that contaminated water, unhygienic facilities, and negligence by authorities had led to the deaths.
Though the Delhi High Court had issued certain directions in 2001, it later closed the matter. The petitioner challenged the closure, seeking sustained monitoring and accountability.
Being seized of the matter, the Supreme Court had, over time, issued a series of interim directions to improve facilities, provide medical support, and ensure adequate food, clothing, and sanitation in Beggars’ Homes, while closely monitoring the progress of these reforms.
Court’s Observations
The Supreme Court held that ensuring dignity for inmates of Beggars’ Homes is a constitutional obligation under Article 21. Referring to past precedents, it noted that the right to life includes the right to live with dignity, care, and humane treatment. “A beggars’ home, maintained by the State, is thus a constitutional trust, not a discretionary charity”, the Court observed.
The Bench noted that over the course of the proceedings, the Apex Court had, from time to time, issued a series of directions to improve conditions in Beggars’ Homes, and noted that the concerned authorities had, by and large, complied with them. It was further observed that “the cumulative effect of these measures has been tangible improvement in infrastructure, health facilities, diet, sanitation, and the overall living conditions of the inmates.”
The Bench also highlighted the need for wider reforms in such facilities and stressed that the reforms achieved in Delhi must be institutionalised nationwide, holding that “The progress achieved should not remain confined to the Homes that were subject to scrutiny in the present case, but must extend to all Homes under the Government of NCT of Delhi. Moreover, all States and Union Territories are required to institutionalise similar reforms in Beggars’ Homes and analogous institutions under their control, so that the constitutional guarantee of life with dignity is meaningfully secured for this most vulnerable section of society.”
The Court therefore issued comprehensive directions to ensure that improved conditions in Beggars’ Homes are not only maintained in the institutions examined but extended across the country. The directions included ensuring proper infrastructure, adequate diet, healthcare, sanitation, and educational and vocational facilities for inmates.
The Supreme Court also stressed the need for regular inspections, accountability mechanisms, and systemic reforms so that Beggars’ Homes function as spaces of rehabilitation and social justice rather than instruments of social control.
Accordingly, the Court directed the Centre, through the Ministry of Social Justice and Empowerment, to frame and notify model guidelines within three months to ensure uniform implementation of the directions across all States and Union Territories.
Conclusion
The appeal was disposed of with directions to the Centre and all States and Union Territories, and with the liberty granted to the parties to seek further directions, should any difficulties arise in the course of implementation.
Cause Title: MS Patter Vs State Of NCT of Delhi & Others (Neutral Citation: 2025 INSC 1115)
Appearances
Amicus Curiae: Senior Advocate Ranjit Kumar