Introduction 

• A bench of Chief Justice DY Chandrachud, Justice JB Pardiwala and Justice Manoj Misra gave slew of directions prohibiting caste-based discrimination in prisons.                

Facts 

• Sukanya Shantha, a journalist at The Wire, authored an article titled "From Segregation to Labour, Manu's Caste Law Governs the Indian Prison System" which exposed caste-based discrimination in Indian prisons. 
• Following her investigation, she filed a Public Interest Litigation (PIL) in the Supreme Court seeking to challenge caste-based segregation in prisons. 
• Her petition specifically requested directions to repeal discriminatory provisions in State Prison Manuals/Rules that violated Articles 14, 15, 17, 21, and 23 of the Indian Constitution. 
• The case came in response to a previous 2014 Madras High Court judgment (C. Arul v. The Secretary to Government) which had accepted the practice of caste-based segregation in Palayamkottai prison. 
• The petition identified three main aspects of caste discrimination in prisons:  
  • Division of manual labor based on caste. 
  • Segregation of prison barracks by caste. 
  • Discriminatory provisions against prisoners from Denotified Tribes and those labeled as "Habitual Offenders". 
• The State Government had previously justified such segregation as a measure to prevent community clashes, particularly in Tirunelveli and Tuticorin Districts. 

Issues Involved   

• Whether prison authorities' practice of segregating inmates based on caste identity, justified as a measure to prevent conflicts and maintain discipline, is constitutional and compatible with fundamental rights guaranteed under Articles 14, 15, 17, 21, and 23 of the Indian Constitution. 
• Whether using vague and indeterminate criteria like "habit," "custom," "superior mode of living," and "natural tendency to escape" as a basis for classifying prisoners serves as a valid differentia or merely acts as a proxy for caste-based discrimination against marginalized communities. 

Observations 

• The Court held that caste-based segregation in prisons, even when justified under the pretext of maintaining discipline, violates the fundamental constitutional guarantees and perpetuates discrimination against marginalized communities. 
• The Court expressly rejected the "separate but equal" doctrine, holding that such philosophy has no place under the Indian Constitution and cannot be used to justify caste-based segregation in prisons. 
• The Court observed that prison authorities' duty to maintain discipline cannot be discharged at the cost of violating fundamental rights and correctional needs of inmates, states that alternative non-discriminatory measures must be adopted. 
• The Court found that criteria such as "habit," "custom," "superior mode of living," and "natural tendency to escape" used for prisoner classification were unconstitutionally vague and indeterminate, serving merely as proxies for caste-based discrimination. 
• The Court held that classification based on caste identity, whether direct or indirect, is proscribed under the Constitution except for limited purposes of promoting equality and social justice. 
• The Court determined that there exists no rational nexus between caste-based classification of prisoners and the legitimate objectives of security, reform, or rehabilitation, rendering such classification arbitrary and unconstitutional. 
• The Court noted that segregation based on caste would reinforce rather than remedy caste differences and animosity, thereby undermining the rehabilitative objectives of the prison system. 

Conclusion  

The Supreme Court declared caste-based segregation in prisons unconstitutional and mandated comprehensive reforms across all States and Union Territories, establishing a monitoring mechanism to ensure compliance and prevent discrimination within the prison system. 

[Original Judgment]