The Madras High Court has held that prisoners are entitled to periodic medical examinations and a diet suited to their individual health conditions as part of their right to life under Article 21 of the Constitution.
A Division Bench comprising Justice G.R. Swaminathan and Justice R. Kalaimathi observed that prison authorities, having complete custody and control over inmates, are under a duty to ensure timely diagnosis, appropriate medical treatment, and reasonable accommodation for prisoners’ health needs in Kalai Selvi v. State of Tamil Nadu.
Diet Must Be Condition-Specific
The Court clarified that a uniform diet for all prisoners is impermissible. It held that dietary provisions must vary depending on medical requirements. For instance, inmates suffering from renal ailments may require low-salt food, while those with diabetes must be provided a specialised diet plan.
The Bench emphasised that food served in prisons must correspond to each inmate’s “unique body condition.”
Case Background
The ruling arose from a petition filed by Kalaiselvi, who sought 28 days’ ordinary leave without escort for her father Murugesan, a 67-year-old life convict lodged in Palayamkottai Central Prison.
Murugesan had been in custody for over six years and underwent amputation of his right leg on October 10, 2025, following diabetes-related complications, including vascular damage and severe ulceration.
Right to Periodical Medical Check-Up
The Court held that access to regular medical screening forms an integral part of Article 21. It observed that periodic check-ups are necessary to identify health conditions at an early stage.
In the present case, the Bench noted that timely diagnosis, appropriate intervention, and a suitable diet could have prevented the deterioration of Murugesan’s condition.
Dignity and Disability Accommodation
Reiterating that incarceration does not extinguish fundamental rights, the Court stated that prisoners continue to retain dignity. It held that prison authorities must accommodate inmates with disabilities and ensure necessary facilities.
Such obligations, the Bench clarified, are enforceable through writ jurisdiction.
Reliance on Supreme Court Precedents
The Court relied on precedents of the Supreme Court of India, including:
- L. Muruganantham v. State of Tamil Nadu
- Sathyan Naravoor v. Union of India
It directed that the principles laid down in these decisions be implemented wherever applicable.
Directions for Systemic Reforms
To strengthen prison healthcare infrastructure, the Court issued the following directions:
- The Superintendent, Central Prison, Palayamkottai, must conduct a comprehensive health check-up for all inmates once every two years.
- The Dean, Government Medical College Hospital, Tirunelveli, must organise a medical camp to identify prisoners suffering from diabetes and provide necessary treatment, including insulin.
Reliefs Granted to Murugesan
The Court directed that Murugesan be provided:
- a cot and table
- appropriate toilet facilities
- counselling and periodic medical monitoring
- assistive devices
- accommodation in an accessible block
- assistance from another inmate, if required
The Bench also referred to reforms associated with Kiran Bedi’s tenure at Tihar Jail and expressed hope that Palayamkottai Central Prison evolves into a model institution respecting the rights of disabled prisoners.
Leave Granted
The Court granted Murugesan 28 days’ ordinary leave without escort from February 28 to March 27, subject to:
- weekly reporting before the SIPCOT Police Station, Thoothukudi district, and
- adherence to the Jail Manual
Appearance
- For the petitioner: Advocate S.M. Mohamed Yunnis Raja
- For the State: Advocates R. Alagumani and T. Senthil Kumar
