Rudul Sah vs State of Bihar, (1983) 4 SCC 141
Rudul Sah v. State of Bihar
Citation: (1983) 4 SCC 141
Supreme Court of India
Date: 1983
🔹 Facts
Rudul Sah was illegally detained in prison for over 14 years despite being acquitted by a competent court.
He had been held in custody even after the order of his release was passed.
The case raised a serious question about illegal detention and violation of personal liberty under Article 21 of the Constitution of India (Protection of life and personal liberty).
🔹 Issues
Whether the prolonged illegal detention violated Article 21.
Whether the state was liable to compensate the victim for illegal detention.
The scope of compensation as a remedy for violation of fundamental rights.
🔹 Judgment
The Supreme Court held that illegal detention is a grave violation of personal liberty guaranteed under Article 21.
The Court directed the State of Bihar to pay compensation to Rudul Sah for the illegal detention.
This case was among the first instances where the Supreme Court awarded compensation as a remedy for violation of fundamental rights.
The Court emphasized that the right to personal liberty includes freedom from illegal detention.
The judgment laid down that compensation is a recognized remedy alongside writs like habeas corpus.
The Court noted that such illegal detention amounts to state wrongdoing for which the victim must be compensated.
🔹 Significance
Marked a major development in human rights jurisprudence in India.
Established compensation as an effective remedy for violation of fundamental rights.
Reinforced the protection of Article 21 – Right to life and personal liberty.
Highlighted the state's liability and accountability for unlawful acts.
Inspired later PILs and judgments focusing on government accountability and human rights.
🔹 Key Takeaway
| Aspect | Rudul Sah Case |
|---|---|
| Violation | Illegal detention, breach of Article 21 |
| Remedy | Compensation awarded to victim |
| Legal Importance | Recognition of monetary compensation as a fundamental rights remedy |
| Impact | Strengthened enforcement of personal liberty and state accountability |
Do write to us if you need any further assistance.
RELATED Blog
0 comments