Introduction
In Indian legal history, the case of Rudal Shah v. State of Bihar has come up as a landmark judgment. It crucially frame the outline of criminal jurisprudence. In this case, Supreme Court dealt with crucial issues related to the rights of prisoners.
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 serve in prisoned for a long time than his sentence given by the court. Petitioner filed a habeas corpus write to produce the body and said that the detention was unconstitutional.
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 violating his fundamental rights.
The petitioner, Rudal Shah, was guilty for the murder of his wife. After completing his sentence in prison, he was acquitted by the Sessions Court in Bihar, on June 3, 1968. In-spite of this, on October 16, 1982, he was released from prison which was over 14-year sentence.
Rudal shah filed a writ of habeas corpus under Article 32 for compensation because of his wrongful detention. He also requested state-funded medical treatment and an ex-gratia (by favour) payment for his recovery.
Legal Arguments
Delay in Execution and Cruel and Inhuman Treatment:
Rudal Shah's primary argument rested on the prolonged delay in the releasing from the prison. He said that such delay, can be cause of psychological trauma of coming execution, amounted to cruel and inhuman treatment, infringing upon his fundamental rights.
Right to Life and Personal Liberty:
The case deals into the extended interpretation of the right to life and personal liberty preserve in Article 21 of the Constitution. The question arise before the court was whether the right to life extended beyond mere physical existence to encompass a life free from unnecessary mental and emotional suffering.
Rudal Shah argued that the prolonged incarceration, aggravated by the uncertainty of execution, compromised the essence of a dignified life, warranting judicial intervention to protect his constitutional rights.
Supreme Court's Decision and Rationale
The judgment delivered by Justice P.N. Bhagwati, acknowledged the profound facts of the case and rendered into a decision that went beyond the immediate facts. The court held that the right to life and personal liberty under Article 21 was not limited to mere physical existence but also included the right to a life with human dignity.
Issues Raised
- Can a person is allowed for damages for illegal detention under Article 32 of the Constitution?
- Right to compensation for the infringement of fundamental rights comes under the of Article 21?
Conclusion
Rudal Shah v. State of Bihar remains a watershed in legal history, where the judiciary recognized the inherent dignity of every person, even those who facing the gravest of punishments. The case's legacy leaving an indelible mark on the broader understanding of fundamental rights and the constitutional commitment to human dignity.
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