Bench:
- Chief Justice Y.V. Chandrachud
- Justice A.N. Sen
- Justice R. Misra
Facts:
In 1953, Rudul Sah was arrested on charges of murdering his wife. On June 3, 1968, the Additional Sessions Judge of Muzaffarpur acquitted him, ordering his immediate release. Despite this acquittal, Sah remained incarcerated until October 16, 1982, resulting in an additional 14 years of unlawful detention. In response, Sah filed a habeas corpus petition under Article 32 of the Indian Constitution, seeking his release and compensation for the violation of his fundamental rights.
Issues:
- Whether the prolonged detention of Rudul Sah after his acquittal constituted a violation of his fundamental rights under Article 21 (Right to Life and Personal Liberty) of the Constitution.
- Whether the Supreme Court has the authority under Article 32 to award monetary compensation for the violation of fundamental rights.
Arguments:
- Petitioner’s Arguments: Sah argued that his continued detention after acquittal was illegal and violated his fundamental rights under Article 21. He sought immediate release and compensation for the unlawful imprisonment.
- Respondent’s Arguments: The State of Bihar acknowledged the wrongful detention but contended that Sah’s release was delayed due to administrative lapses. The State also argued that monetary compensation should be sought through a civil suit rather than a writ petition under Article 32.
Ratio Decidendi:
- Violation of Fundamental Rights: The Supreme Court held that Sah’s prolonged detention after acquittal was a clear violation of his fundamental right to life and personal liberty guaranteed under Article 21.
- Award of Compensation under Article 32: The Court established that it possesses the authority to award monetary compensation under Article 32 as a remedy for the violation of fundamental rights. It emphasized that such compensation serves as a necessary relief to ensure the enforcement of fundamental rights and to deter future violations by the state.
Observations:
- State Accountability: The Court underscored the responsibility of the state to protect individual rights and held that administrative lapses leading to unlawful detention cannot be justified.
- Scope of Article 32: The judgment broadened the scope of Article 32, allowing the Supreme Court to grant remedial relief, including monetary compensation, for the enforcement of fundamental rights.
Decision:
The Supreme Court ordered the immediate release of Rudul Sah and awarded him compensation of ₹30,000 for the 14 years of unlawful detention. Additionally, the Court granted ₹5,000 to cover Sah’s expenses for medical treatment and rehabilitation. The Court also directed the State of Bihar to initiate proceedings to investigate the circumstances leading to Sah’s prolonged detention and to take appropriate action against those responsible.
Important Terms:
- Article 21 of the Constitution: Guarantees the right to life and personal liberty, stating that no person shall be deprived of these rights except according to the procedure established by law.
- Article 32 of the Constitution: Provides individuals the right to approach the Supreme Court for the enforcement of fundamental rights, empowering the Court to issue directions or orders, including writs like habeas corpus.
- Habeas Corpus: A legal writ requiring a person under arrest to be brought before a judge or into court, ensuring that a prisoner can be released from unlawful detention.
- Monetary Compensation: Financial reparation awarded to an individual for loss or injury suffered due to the unlawful actions of another party, in this case, the state.
