'There is no greater tyranny than that which is perpetrated under the shield
of the law and in the name of justice.'-Charles-Louis de Secondat
The recent deaths in custody of two men in Tamil Nadu has once again spotlighted
the perennial malady of police violence. One of the worst failures of justice
system was the case of Father Stan Swamy whose ill-treatment led to his death in
prison in July 2021. The Nordic countries have one of the lowest recidivism
rates in the world. Quite interestingly, they have the softest prison rules
which aims to ensure smooth entry of criminals into the real world and not like
other countries treating prisoners like dirt and mollycoddling them which
results in them coming out dirty and offending again.
The issue of authorities abusing and torturing the prisoners dominated headline
in 2021 due to the tragic death of 84-year-old tribal activist Stan Swamy. The
National Investigation Agency (NIA) and the prison authorities went to great
lengths to deny him bail and the most basic of necessities which he needed as an
old man suffering from Parkinson's. According to various testimonies by the
former inmates there, the prisoners were left to just animal existence and were
cramped up liked caged animals without any basic healthcare facilities and that
too in a prison where majority of the inmates are undertrials. We are already
very late in acknowledging the human rights of prisoners advocated by many
organizations such as the UN and the Human Rights watch when these rights have
been accepted in many countries of the world.
This article aims to deal with the justice machinery involved be it the prison
authorities or the magistrates who more often than not fail to deliver the
needful and seeks to fix accountability on their part. This article seeks to
analyse this through the lens of the much-ignored Stan Swamy's case to do
justice to him and to million others who have fallen prey to this misery time
and again. There are multiple angles and reasons for the death of India's oldest
terror accused (like the draconian UAPA, denial of medical bail, harassment of
under trials etc.) but the mismanagement on the part of the prison authority and
the judges is colossal. So, with Swamy's case at hand this article will
highlight the major flaws in the Indian Judicial and Prison system and the
immediate need to address them before another person succumbs to torture by the
bleak justice system.
Father Stan Swamy was the oldest and the last person to be arrested in
connection with the Elgar – Parishad – Bhima Koregaon case with alleged Maoist
links. He was a Jesuit priest and a very active tribal rights activist. He was
put in Mumbai's Taloja jail in Mumbai on October 8, 2020, by the NIA. Stan Swamy,
owing to his age and medical ailments, was very weak and needed proper medical
attention. He had Parkinson's, lumbar spondylosis, had undergone two hernia
operations, had frequent periods of memory loss and his hearing was impaired but
it still took 50 days for NIA and the jail authorities to provide him with a
sipper and a straw.
He was also tested positive for Covid on May 30,2021.
The NIA Court kept rejecting his bail pleas and failed to acknowledge his
deteriorating medical condition in the jail. All these arrests and foul play for
a case which is apparently meritless in wake of substantive evidence coming up
like the report by Arsenal Consulting, a US-based digital forensics consulting
company, which concluded that the computers of many accused were "infected with
a malware" and the documents found were planted.
The Taloja jail factor:
The prison authorities failed miserably in their duty of care towards Stan Swamy
and left him in the prison to rot. Firstly, when Swamy was arrested, his custody
was not sought by the NIA even once. Charges as serious as plotting to kill the
Prime Minister should have made NIA interrogate the arrestee in due course of
time but the glaring omission on its part is reprehensible.
- When, owing to the covid-19 scare, all other prisons were being emptied,
Maharashtra's Taloja jail at that was too overcrowded as it had a capacity
of 2124 against the then intake of over 3000 prisoners which shows its
neglect of health care conditions of Prisoners. Adding to the injury, the
prison had just 3 ayurvedic doctors at the disposal of the 3000 people.
Now this is a problem that is consistently hampering the justice
administration system: The problem of overcrowded prisons. The most recent
Prison Statistics Report 2019 by the National Crime Record Bureau shows that
the number of prisoners exceeding the capacity of prisons in India have been
the highest in this decade which is a problem of concern. According to the
report, as on 31 December 2019, the total capacity of India's prisons stood
at 4, 03,700 while the number of prisoners stuffed in these prisons are 4,
78,600: a whopping 118.5%.
The report highlights the medical negligence on the part of prison officials
also and according to the same report 13.2% of the prisoners are above 50
which in this pandemic can be disastrous owing to the constant movement of
prisoners from one prison to another and also being released and then
detained which will lead to them being spreaders of this virus. A total of
1,775 prisoners died in India during 2019, while they were in custody. Out
of this, 1,544 were natural deaths which anyways get affected by the prison
atmosphere, while 165 were categorized as unnatural deaths.
Dr. Kafeel Khan, who was charged under NSA back in 2020 for his anti CAA
(Citizenship Amendment Act) speech wrote a letter in which he described the
deplorable state he was living in. Relaying the dangerous prison conditions,
Dr. Khan wrote, "With just one attached toilet, 125-150 inmates, the smell
of their sweat and urine mixed with unbearable heat due to electricity cuts
makes life hell over here: A living hell indeed. …It sometimes feels that I
might fall due to dizziness caused by that suffocation. So, I keep on
drinking water. In a jail made for 534 inmates, there are 1,600 people kept
with one barrack holding at least 100-125 of us. There are just 4-6
- It is no surprise that these ayurvedic doctors had prescribed certain
allopathic medicines to Swamy that were allegedly not meant for his illness.
The Bombay high court took a note of the scarcity of doctors in Mumbai's
prisons. The Gujarat High Court in Rasikbhai Ramsun Rana vs. State of
Gujarat((1999) 1 GLR 176) ordered all central and district prisons to be
equipped with an ICCU, pathology lab, expert physicians, sufficient staff
including nurses, and the most up-to-date medical treatment devices. Leave
the most updated treatment devices, here, in Taloja; a patient with a
chronic disease doesn't have an MBBS doctor at his disposal.
In the case of T.V Vatheeswaran v the State of Tamil Nadu (1983 AIR
361) it was pointed out that Articles 14 (right to equality), 19 (right to
free speech and expression) and 21 (right to life and liberty) are as much
available to prisoners as to freeman. But the Indian picture gives a
contradictory image. The Indian Justice report 2019 shows how prisoners have
a lower mortality rate and are easily exposed to several diseases with below
par focus on the health of inmates.
According to the Indian Justice Report of 2019 by Tata Trusts:
Against the sanctioned 10 posts, Uttarakhand had no medical officer. Barring the
Andaman and Nicobar Islands, Chandigarh, Goa, Kerala, Meghalaya, Nagaland,
Puducherry and Tripura, twelve states and UTs had a shortfall of 50 per cent or
more medical officers available.
The problems of overcrowding of prisons plus shortage of medical officers are
highly alarming when covid cases have yet started to rise and is a serious
threat to the life of the prisoners.
The International human rights agencies have called for just and humane
treatments to prisoners. According to "A Pocketbook of International Human
Rights Standards for Prison Officials" by United Nations - Medical personnel
have a duty to provide prisoners and detainees with health care equal to that
which is given to those who are not imprisoned or detained . This in India is a
distant dream. And to highlight that subjecting the inmates to all kinds of
unhealthy and depressing environment is no short of torture and that too in a
prison where most of the prisoners are under trial.
In the words of Stan Swamy himself to the court on his bail hearing on May
21,2021 : " Eight months and my health and bodily functions have severely
deteriorated, before I was lodged in Taloja prison , my body was functional...I
am requesting you to consider how this deterioration happened" . That's what an
ignorant and lax justice system does to you.
Prison condition in India:The Problem of the Undertrials
This case also raises a big question mark on the criminal justice system of
India which works on the principle of innocent until proven guilty. When the
prosecution in this case kept arguing from the sides of NIA to not grant the
interim bail to Swamy, the overriding common sense of legal prospects were
buried deep inside. Prisoners have basic legal rights that cannot be snatched.
The basic rights include right to food and water, right to timely medical
examinations, protection from torture etc.
But Indian prisoners have witnessed some of the harshest use of power and
gravest denial of human rights. According to the Prison statistics of India 2019
by the NCRB, "the share of convict prisoners is much lower, as compared to the
undertrials (69.05%). Not since 1980 has the proportion of undertrial prisoners
dipped below 60%. In some states like Delhi and Bihar, eight of 10 prisoners are
undertrials, according to 2019 NCRB data. It mainly determines the overcrowding
of prisons in various jails in the state/UT".
Also, placing undertrials and convicts together is an abuse of human rights.
Keeping them in same prison and subjecting them to same punishments is equal to
treating them as guilty goes against the Prison Act of 1894 which calls for
separation of convicted and unconvicted prisoners which is absent in most of the
prisons in India, let alone the Taloja jail.
All these instances give rise to travesty of justice. Innocents languishing in
jails for all their lives and their cases not being taken up. In Swamy's case
itself the court delayed the hearing till that date when it finally got the news
of his demise.
In the Supreme Court case of Joginder Kumar v State of UP
, the Supreme
Court pointed out that arrests should be the last resort and the police
authorities should not make it a habitual activity. It will drastically reduce
the overcrowding of prisons especially when majority of the prisoners are
Arrests should be avoided until and unless:
- there is a threat that the accused will not comply with the rules and
- or there is a threat to his/her life,
- or when there is a likelihood that the person will not appear in the
- Or the crime which is committed is very grave, so as to stop the person
from repeating such acts.
Further in Arnesh Kumar v State of Bihar and Anr
the Supreme Court made
very strict observations and said "The need for caution in exercising the
drastic power of arrest has been emphasized time and again by Courts but has not
yielded desired result. Power to arrest greatly contributes to its arrogance so
also the failure of the Magistracy to check it.
Not only this, but the power of arrest is also one of the lucrative sources of
police corruption. The attitude to arrest first and then proceed with the rest
is despicable. It has become a handy tool to the police officers who lack
sensitivity or act with oblique motive."
The Court further said that "Apart from power to arrest, the police officers
must be able to justify the reasons thereof. No arrest can be made in a routine
manner on a mere allegation of commission of an offence made against a person."
Here in Swamy's case, he was not even interrogated once. Leave any
justification; it was just abuse of the power of arrest, to silent dissent.
Also, non-completion of speedy trial and investigation is violating the right to
speedy trial of prisoners under article 21 (Fundamental Right of life and
personal liberty) and Section 173 [speedy investigation], Section 309 [speedy
inquiry /trial], Section 437(6) [speedy trial of a person accused of non-bailable
offence] of the CrPC as pointed out in the case of Vakil Prasad Singh v State
In the landmark case of Parmanand Katara Vs Union of India
, the Supreme
Court highlighted that it is the duty of the state to maintain life, be it of a
criminal in a prison or an innocent individual, owing to Article 21 of the
Bailable and Non-Bailable Offences:
Was granting bail to Swamy so impossible that the courts kept rejecting his bail
plea till his death? It is understood that terrorism is a grievous offence and
the arrest under Unlawful Activities (Prevention) Act (hereafter, UAPA),
1967(specifically Section 43D of UAPA) makes it harder to grant bail but in the
present case it needs to be understood that Stan Swamy was an accused not a
convict, so the process of granting bail due to his medical condition and lack
of evidence should have been possible.
Furthermore, taking a look at Section 167 (2)(a)(1) ,under which it is the
statutory right of the prisoner to be released under default bail when the
investigation has not been completed in due time or the magistrate feels that
there are adequate grounds on which the accused may be released. In Swamy's
when the first FIR was registered in 2018, he was not arrested for two
years (until 2020), showed that he was not considered a flight risk or someone
who would tamper with evidence. If that can be ignored, the old and ailing man
was not even released during the devastating second wave too.
On top of that calling his medical reports inconclusive as to grant bail was
nothing but sheer unprofessionalism on the part of the NIA officials which went
against the human rights of the tribal rights activist. Also going against their
action is the judgement of the Bombay High Court which granted bail to the 81
year old co-accused Varavara Rao (in the same Bhima Koregaon case) on grounds of
'ill health, advancing age, and inadequate facilities at Taloja jail hospital' ,
all of the criteria under which Swamy could fit, more so than Rao. Now let us
look at the reasons why bail is near impossible for cases under UAPA.
Section 43D of UAPA act gives the provisions of granting bail which are so
strict that they make bail almost impossible. According to S 43D -
"Notwithstanding anything contained in the Code, no person accused of an offence
punishable under Chapters IV and VI of this Act shall, if in custody, be
released on bail or on his own bond unless the Public Prosecutor has been given
an opportunity of being heard on the application for such release: Provided that
such accused person shall not be released on bail or on his own bond if the
Court, on a perusal of the case diary or the report made under section 173 of
the Code is of the opinion that there are reasonable grounds for believing that
the accusation against such person is prima facie true."
Adding to the woe came the famous, rather the infamous Zahoor Watali judgement,
In 2019 in which the Supreme Court said that the courts must take the state's
case as true in the case of granting bail (in UAPA cases), without looking at
the merits. This means all that is written in the FIR must be seen as true,
prima facie, while granting bail. This goes directly against the innocent until
proven guilty rule of the Indian justice system as in UAPA cases the person is
guilty until proven innocent which makes it even difficult for the person to get
bail as allegations are hard to disprove. And this has given edge to the NIA
which has made the 16 accused to rot in jail just on the basis of some tampered
and planted "inadmissible evidence".
In the same year, the Delhi High Court granted bail to three student activists
namely Asif Iqbal Tanha, Devangana Kalita, and Natasha Narwal arrested under
UAPA for allegedly taking part in the Delhi Riots of 2020 February. They were
booked under section 15 of the UAPA (Terrorist Act) . Even after the court
granted them bail, the police authorities did not release them giving the reason
that they needed more time for the address verification of the accused. This
shows the lack of intent on the part of state machinery which needs reasons for
keeping people in the prisons, which is an extremely dangerous sign for a
In the case of Shaheen Welfare Association v Union of India and Ors.
Supreme Court observed that: "No one can justify gross delay in disposal of
cases when undertrials perforce remain in jail, giving rise to possible
situations that may justify invocation of Article 21."
Also in the case of Sanjay Chandra v the CBI , the Supreme Court took very
strict observations and held that : "In this country, it would be quite contrary
to the concept of personal liberty enshrined in the Constitution that any person
should be punished in respect of any matter, upon which, he has not been
convicted or that in any circumstances, he should be deprived of his liberty
upon only the belief that he will tamper with the witnesses if left at liberty,
save in the most extraordinary circumstances……….
In our view, seriousness of the charge is, no doubt, one of the relevant
considerations while considering bail applications but that is not the only test
or the factor: the other factor that also requires to be taken note of is the
punishment that could be imposed after trial and conviction."
Furthermore, the Supreme Court very rightly highlighted a very important point
regarding bail and the gravity of offence in the case of P. Chidambaram vs.
Directorate of Enforcement: "The gravity can only beget the length of sentence
provided in law and by asserting that the offence is grave, the grant of bail
cannot be thwarted"
In another case, the Supreme Court highlighted a very different reason to grant
bail to the accused. The Court in Babu Singh v State of U.P said that "It makes
sense to assume that a man on bail has a better chance to prepare or present his
case than one remanded in custody. And if public justice is to be promoted,
mechanical detention should be demoted."
Accountability of prison authorities
The law needs to make sure that people come to prisons for free and fair trail
and not as punishment itself. In the landmark case of D.K Basu , SC has laid
down prison guidelines which mandate the medical examination of the arrestee by
a trained doctor every 48 hours during his detention in custody. The SC did not
intend a cursory or visual examination but a more detailed exercise. Leave aside
regular examination, Swamy failed to receive the slightest intend of care from
Gautam Navlakha, booked under similar charges, was denied spectacles in jail
without which he claimed he was completely blind. His family members claimed
that his spectacles were stolen inside the Taloja prison and when they sent a
pair of new spectacles to him by post, the prison authorities refused to accept
it and sent it back. A division bench of Justices S S Shinde and M S Karnik of
the Bombay HC observed that "Humanity is most important. Everything else will
Justice Shinde further said," Can all these small items be denied? These are all
humane considerations. This is the high time to conduct a workshop for even jail
authorities." The prisoners have come to the prison to serve their term but
torturing them again by not providing them with the things without which they
can't do their day-to-day activities is like punishing them twice for the same
Accountability breeds response-ability and the severity of human rights
violation demands the culprits of justice system to meet the consequence of
their acts. In exercise of the powers conferred by subsection 25 of section 59
of prison act 1894, the state government has framed rules regarding appointments
and visits by official and non-official visitors. Low inspection rates give rise
to laxity on the part of in-charges of prisons. There must be more frequent
visits by ex-officio such as collectors, district and sessions judges etc. and
also by non-officials and members of human rights commission.
Health care system of prisoners should be timely monitored. District and High
courts should timely summon prison authorities for knowing the on-ground
The undertrials must also be heard routinely by a high-level officer on the way
they are treated inside the prison. Gross injustices often take place only when
there is no one to be accountable to. Also, the complete dilution of the ways of
treatment of convicted and non-convicted must go. A person who is merely an
undertrial deserves a more favorable treatment. There cannot be a similar
treatment of an innocent and a guilty when law almost is all about distinction
between the two.
At the heart of every above-mentioned problem, is the problem of pendency of
cases in Indian courts for which people suffer to the point that after spending
20 years in jail, a person is finally declared not guilty by the court. It's
just one of the many ways in which the system is destroying the lives of people.
As of July 2021 there were 39.38 million pending cases in the district courts of
India (including both Civil and Criminal cases) adding to that high courts in
India have 5.86 million cases to dispose which brings the total to 43.9 million
cases, which is huge.
And Supreme Court also as of 2 July 2021 had 69,212 cases at hand which are
pending (of which 13,452 cases cannot be listed for hearing in the court, which
brings the total to 55,670, which too is a staggering number for a mere 34
judges). Taking a look at the number of current vacancies that need to be filled
up to at least reduce the number of pending cases if not lower them. The Supreme
Court is short of 7 judges out of 34 (21% vacancy), the high courts are short of
record 449 judges (41% vacancy) and the district court maintain a staggering
number of 5000 empty posts of Judicial officers.
Therefore, with these many cases at hand, and the courts short of a large number
of judges and officers, it becomes almost impossible to solve these many pending
cases and end the suffering of millions of undertrials and those who are not
guilty but are still rotting in jails. The courts need to address this issue in
a fast-paced manner and try recruiting people at a faster pace.
With all these problems not being currently taken up, the legislature or the
judiciary should address the following two questions with utmost urgency:
- How long will the undertrials have to languish in jail, while their
cases are pending in the courts? (Human Rights of prisoners should not
suffer due to a weak justice system)
- Why can't we make correctional facilities for the undertrials and reduce
their suffering by not treating them equal to prisoners in jail? (The point
is that they are still innocent and therefore should not be treated any
differently than a normal person and that too just on the basis of prima
facie charges, which in all its probability may be wrong)
In India, retribution is becoming the basis of punishment when rehabilitation
should be the goal. The prison system is an important part of justice system and
hence it must subscribe itself to the just ways. The objective of punishment is
to deter future commission of crime but the stringent handling and constant
torture to the prisoners badly affects them.
And the aim of establishing an independent Judiciary is to prevent the misuse of
power by the other two branches of the government, viz Legislature and the
Executive. And when the Judiciary closes its eyes and lets injustice happen,
then all hell will break loose, and the democratic machinery will collapse.
This Indian Justice System needs a complete overhaul and should not consume
another person in the garb of saving the "society". A mere 69 rank out of 128 in
the Rule of Law index by WJP is just a pathetic but a real image of how hollow
India's justice system is. The same index was topped by Denmark which also holds
the 2nd position in the Happiness index. It is obvious where there is minimal
corruption and where the justice system is running without any interference from
outside, the citizens will have a happy and peaceful life, which should also be
the goal of governments around the world and that can only happen by filling up
the holes in the system before it's too late.
There is no reason as to why an ailing 84-year-old man in such a grave situation
should not have been given bail. The HC's dismissiveness of the severity of his
health condition is a gross negligence. Also, lack of any prima-facie evidence
against Swamy and knowing his contribution as an activist could have been some
distant basis in granting him bail. The price of the laxity of the justice
system is the life of a tribal rights activist.
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- Shruti Parashar - 3rd Year Law Students Of RMLNLU And
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