Case Details
| Case Name | Rudul Sah vs State of Bihar |
| Case Number | Writ Petition (Criminal) No. 1387 of 1982 |
| Jurisdiction | Supreme Court of India |
| Bench | Justice Y.V.Chandrachud, Justice Amrendranath Sen, Justice Rangnath Misra |
| Appellant | Rudal Shah |
| Respondent | State of Bihar |
Introduction
In the legal series of the cases, this Rudal Shah v. State of Bihar has come up as a landmark judgment. It is an important judgement which sets out the framework of criminal jurisprudence. Basically, this case deals with some of the very crucial problems in the Indian prison system.
It dealt with the rights of prisoners which talks about the inhuman treatment with them and infringement of their fundamental rights. It was also concerned with access to justice and the right to life and personal liberty under article 21 of the Indian Constitution.
Factual Background
The case is related to false imprisonment which revolves around Rudal Shah, (prisoner) who had spent over 14 years in prison. He served more time in prison than his sentence given by the court. The “Petitioner” filed a writ of habeas corpus in order to produce the body. He also said that the detention was unconstitutional according to the law.
Petition filed in the Supreme Court under Article 32 of the Constitution, asserting that the extreme delay in the releasing of that person amounted to cruel and inhuman treatment which violated his fundamental rights.
The court held the petitioner liable for the murder of his wife. Later on, when he completed his sentence in prison. On the date of “June 3, 1968”, the Session Court of Bihar passed the order of his release, which means now the authority can release the person because he spent his whole sentence.
In-spite of this, he was released on October 16, 1982 which was over a 14-year sentence. Means he spent 14 years extra in jail or prison, without any reason. It was a wrongful detention by the state, that is why for getting compensation “Rudal Shah” has filed a suit under writ of habeas corpus. He also requested state-funded medical treatment and an ex-gratia (by favour) payment for his recovery.
Legal Issues
1. This is one of the main questions before the court that whether “Rudal Shah” is entitled to get compensation or not? Because there is an unlawful detention of the citizen.
2. Article 21 of the constitution guarantees right to life and personal liberty, so will the act of unlawful detention come under the ambit of article 21 or not?
3. Whether an Indian citizen can take any action against the arbitrariness of the state or not.
4. If the fundamental rights of the citizen have been infringed that person can use Article 32 of the Indian constitution or not, for getting compensation.
Supreme Court's Decision or Judgement
The Supreme Court of India has highlighted the major issues in this order. It talks about the unconstitutional detention, state’s responsibility, damages for the fake detention and many other things which we have discussed below:
The Supreme Court in its judgement clearly said that imprisonment of rudal shah more than the period of his sentence is considered as illegal detention.
This act has violated the fundamental right of that person, that is to fall under the ambit of Article 21 of the constitution. It was held that the state’s action was arbitrary and unreasonable in nature.
1. Compensation as a Remedy:
Compensation was an essential issue in this case. Even the Supreme Court recognized the right to compensation. However, the constitution does not clearly talk about the compensation but it can come under the authority of Article 32 of the Constitution.
Under this article, if any of the fundamental rights has been violated then the person (whose right infringed) is entitled to get damages for their loss.
“Article 21” played a significant role in this judgement because the case is related to unlawful detention and this article also defined the right to liberty and right to life as fundamental rights. If a state or any other person deprived anyone from this right then it will be considered unlawful or against the constitution of India. The violator of the rights either punished or paid the monetary compensation and both.
2. State Accountability:
This case set forth the accountability of the state, that the state will also be held liable for their unlawful acts. In this judgement of Rudul Shah vs State of Bihar And Another specified that if there is any violation of the fundamental rights of a person this will be punishable under the law.
The state argues that they have special powers of immunities because of that they can not be held accountable. However, the supreme court dismissed the argument of state’s immunity. Held - even the state could not escape from its responsibility.
Compensation: As the court held state accountability, SC gave an order to give a sum of 30,000/- Rs. to rudal shah as a compensation. That is why the state has paid the amount of damages.
3. Judicial Activism:
It is the process where the Court extended their powers to make sure justice is done in true sense. The decision of rudal shah case carved out the path for future cases where the judiciary can take an active role in protecting fundamental rights and providing effective remedies for the violation of it.
Impact of the Judgment
Remedy under Article 32: The case defining the remedial power that is given under article 32 of the constitution. It is stated that if anyone violated the fundamental rights given under part III of the constitution then the person can file a suit (whose right has been infringed).
Influence other Cases: It has become a landmark case that influences other cases of similar facts. It helps to get damages if anyone has violated someone’s legal right. As in the order of this case, the court grants compensation to the victim for the violation of his legal rights. It laid the groundwork for a more proactive approach by the courts in safeguarding the rights of individuals and ensuring that justice is delivered.
Deterrent Effect on State Authorities: This decision conveyed a good impact on the state's authorities. Even states are not immune from the responsibility of it. The judiciary would not tolerate the arbitrary and illegal behavior of the state. It is crucial for protecting the rights of the citizens.
Conclusion
After the case of “Rudal Shah v. State of Bihar” there is vast change made in terms of the liberty and dignity of every person. Even those prisoners, who were facing heinous punishments or inhuman treatment. This case has set the example for the other cases which maintain human dignity.
The court also held that the accountability of the conduct of governance, judges also criticizes the arbitrariness of the state. Stated that there is no right of illegal detention to the state. The jury emphasized on the re-evaluation, administration, penal procedures and governance of the state. That because of the mistake of the authority a person can suffer without any mistake. That is why, the transparency of the state is also held under these circumstances.
