Prisoners Have Fundamental Right To Get Compensation For Work Related Injuries Suffered In Jail: Delhi HC Issues..
Prisoners Have Fundamental Right To Compensation For Work-Related Injuries Suffered In Jail: Delhi HC Issues Directions
Background:
Prisoners, despite their incarceration, do not forfeit their fundamental rights guaranteed under the Constitution of India. This includes the right to life and personal liberty (Article 21), which encompasses the right to health and safety.
In many prisons, inmates are engaged in various work assignments, including manufacturing, kitchen duties, cleaning, etc. Work-related injuries can occur during these activities.
Key Legal Principles:
1. Prisoners Are Entitled to Basic Human Dignity and Protection
The Supreme Court and High Courts have held that prisoners retain all fundamental rights except those necessarily curtailed due to incarceration.
The State has a duty of care towards prisoners, including providing a safe working environment.
2. Right to Compensation for Injuries
If prisoners suffer injuries during work assigned within the jail, they are entitled to compensation for such injuries.
Compensation acts as a remedy for violation of their rights and ensures accountability of prison authorities.
3. State’s Obligation Under Constitutional and Statutory Law
Article 21 ensures protection of life and personal liberty.
The Employees’ Compensation Act, 1923 and Workmen’s Compensation Act principles have been extended to prisoners in certain judgments.
Prison manuals and jail regulations require the State to ensure safe conditions and compensate inmates in case of injury.
Delhi High Court's Observations and Directions:
The Delhi High Court recently directed the concerned authorities to frame clear rules and guidelines for compensation to prisoners who suffer injuries while engaged in jail work.
It emphasized that denial of compensation or neglect in treating prison injuries violates prisoners’ rights.
The Court stressed prompt medical care, proper investigation of incidents, and payment of compensation without undue delay.
Authorities were instructed to maintain records and ensure transparency in the process.
Supporting Case Laws
1. Sheela Barse v. Union of India, AIR 1986 SC 1773
The Supreme Court recognized the fundamental rights of prisoners, including right to life and dignity.
It laid down guidelines for prison reforms, emphasizing humane treatment.
2. Sunil Batra v. Delhi Administration, AIR 1978 SC 1675
Held that prisoners have constitutional protections, and cruel or inhuman treatment is unconstitutional.
This includes protection against negligence causing injury.
3. M.H. Hoskot v. State of Maharashtra, AIR 1978 SC 1548
Affirmed prisoners' right to basic rights and State’s duty of care, including health and safety.
4. Prem Shankar Shukla v. Delhi Administration, AIR 1980 SC 1535
The Court recognized that the prison system must ensure prisoners’ rights, including safe working conditions.
5. D.K. Basu v. State of West Bengal, AIR 1997 SC 610
Though primarily about custodial violence, the judgment emphasizes the State’s obligation to protect persons in custody from harm.
Summary Table:
| Aspect | Legal Position |
|---|---|
| Prisoners’ fundamental rights | Right to life, dignity, health protected under Article 21 |
| Right to compensation | Injuries in jail work attract right to compensation |
| State’s duty | Provide safe working conditions, medical care, and compensation |
| Legal framework | Constitutional law + principles of Workmen’s Compensation Act |
| Delhi HC directives | Prompt compensation, investigation, and transparent processes |
Conclusion:
The Delhi High Court’s ruling reaffirmed that prisoners retain their fundamental rights, including the right to claim compensation for work-related injuries sustained while in jail. The State bears the responsibility to ensure safe working conditions and provide adequate redressal for any harm suffered. This aligns with the constitutional mandate to treat prisoners with dignity and fairness.
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