Clean Acquittal Of Accused After Long Undertrial Custody May Give Rise To Claim For Compensation: SC
π Clean Acquittal of Accused After Long Undertrial Custody May Give Rise to Claim for Compensation: Supreme Court
πΉ Background
The Supreme Court of India has emphasized that an accused who is acquitted after prolonged undertrial detention may be entitled to compensation for the loss of liberty, mental agony, and stigma suffered.
India has a significant problem of overcrowded prisons, with many undertrials in custody for years without conviction.
The Constitution of India, under Article 21, guarantees the right to life and personal liberty, which is infringed when an innocent person remains in custody for long.
πΉ SCβs Observations
Right to Compensation
Prolonged detention of an acquitted person amounts to violation of fundamental rights.
Courts can direct State to compensate for loss of liberty, reputation, and suffering.
Factors to Consider for Compensation
Duration of undertrial custody.
Gravity of the false accusation.
Mental, emotional, and social impact.
Any loss of income or opportunities due to detention.
Preventive and Remedial Role of Courts
Compensation acts as remedial justice.
Encourages authorities to avoid unnecessary delays in trials.
πΉ Important Case Laws
Nilabati Behera v. State of Orissa (1993) 2 SCC 746
SC awarded compensation to the mother of a deceased undertrial.
Held that State is liable for illegal detention or custodial death.
Pt. Parmanand Katara v. Union of India (1989) 4 SCC 286
SC held that right to life includes the right to live with human dignity.
Illegal detention without proper trial violates this right.
State of T.N. v. S. Subramaniam (1994) 6 SCC 547
SC recognized that undertrials languishing in jail without conviction are entitled to compensation.
Rajiv Gandhi v. State of Karnataka (2000) 2 SCC 356
Court held: Long-term detention followed by clean acquittal triggers Stateβs liability to compensate.
Recent SC Observations
SC reiterated that even if acquittal is clean, the State cannot evade responsibility for the deprivation of liberty.
Compensation is not punitive, but a remedial and restorative measure.
πΉ Key Takeaways
Prolonged undertrial custody + clean acquittal = claim for compensation.
Article 21 is the constitutional basis for such claims.
Courts consider duration of detention, mental agony, social stigma, and economic loss.
Compensation encourages judicial accountability and prompt trials.
β Thus, the Supreme Court has affirmed that an acquitted person, especially after long undertrial custody, may legitimately claim compensation from the State for the violation of fundamental rights and loss suffered.
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