The Supreme Court of India, on October 3, 2024, declared that provisions in state prison manuals enabling caste-based assignment of labour to prisoners are unconstitutional. A Bench comprising Chief Justice D.Y. Chandrachud, Justice J.B. Pardiwala, and Justice Manoj Misra held that the practice of assigning menial and sanitation work to prisoners from Scheduled Castes and other marginalised communities while reserving cooking and other duties for upper-caste prisoners violates Articles 14, 17, and 23 of the Constitution. The Court directed all states to review and amend their prison manuals to eliminate caste-based classifications.
Background
The petition was filed by journalist Sukanya Shantha, drawing on investigative reporting that documented the persistence of caste-based labour division within Indian prisons. The petition highlighted provisions in the prison manuals of several states — including Uttar Pradesh, Madhya Pradesh, West Bengal, and Tamil Nadu — that explicitly or implicitly assigned categories of prison work based on the caste identity of inmates.
Under these provisions, prisoners from Scheduled Castes were routinely assigned sweeping, cleaning, and sanitation duties, while cooking and other relatively less stigmatised tasks were reserved for upper-caste prisoners. The petition contended that this institutional practice perpetuated the very system of untouchability that Article 17 of the Constitution expressly abolishes, and that the assignment of menial labour based on birth constituted forced labour prohibited under Article 23.
Key Holdings
The Supreme Court delivered the following rulings:
Article 17 extends to institutional practices: The abolition of untouchability under Article 17 is not limited to traditional social settings but extends to all institutional contexts, including prisons. Caste-based assignment of labour within the prison system constitutes a practice of untouchability in violation of Article 17.
Caste-based classification violates Article 14: Prison manual provisions that classify prisoners by caste for labour assignment fail the test of reasonable classification under Article 14. Caste identity bears no rational nexus with the type of work a prisoner is capable of performing.
Forced labour under Article 23: Assigning menial and degrading work to prisoners based on caste amounts to forced labour prohibited under Article 23. The Court observed that compulsion need not be physical — the structural coercion inherent in the prison system, combined with caste hierarchy, creates conditions of forced labour.
Direction to amend prison manuals: All state governments and Union Territory administrations were directed to review their prison manuals and eliminate every provision that enables, permits, or facilitates caste-based assignment of labour or segregation of prisoners by caste.
Compliance timeline: States were given a defined timeline to complete the review and amendment of prison manuals and to submit compliance reports to the Supreme Court.
Implications for Practitioners
This judgment extends the reach of anti-discrimination jurisprudence into the closed environment of custodial institutions. Prison law and human rights practitioners now have a clear constitutional mandate to challenge caste-based practices within any institutional setting, drawing on the Court's expansive reading of Articles 17 and 23.
For state governments and their legal advisors, the direction to amend prison manuals requires a comprehensive audit of existing regulations. The exercise is not limited to explicit caste references — the Court's reasoning captures indirect classifications and practices that produce caste-based outcomes even without express caste-based language in the manual provisions.
The judgment's treatment of structural coercion as satisfying the "force" element under Article 23 is particularly noteworthy. This reasoning may have implications beyond the prison context, potentially applicable to other institutional settings such as manual scavenging, bonded labour in agricultural contexts, and labour practices in state-run institutions. Practitioners working on labour rights and anti-discrimination law should track the compliance reports filed by states, as non-compliance may open further avenues for enforcement litigation.