The severe overcrowding in closed prisons creates inhuman conditions that violate the fundamental right to life and dignity (Article 21). A permanent mechanism is required to monitor and decongest these facilities.

The Amici Curiae argued that strengthening Open Correctional Institutions (OCIs) is the most viable and sustainable measure to address both overcrowding and prisoner rehabilitation.

They presented data showing that existing OCIs are drastically under-utilized across the country. Furthermore, current practices cause social inequities, specifically highlighting the discriminatory exclusion of women from OCI facilities.

The Union submitted that it has actively engrafted and circulated normative guidelines, specifically the Model Prison Manual, 2016 (containing a dedicated chapter on OCIs), and the Model Prisons and Correctional Services Act, 2023.

The Union argued that since “prisons and persons detained therein” falls under the State List (Seventh Schedule of the Constitution), it is the primary responsibility of the respective State Governments and Union Territories to take policy decisions, allocate funds, and physically establish or expand OCIs.

Various states defended their restrictive practices—such as requiring 12 to 21 years of prior incarceration, prohibiting family cohabitation, or entirely excluding women from OCIs—by citing management difficulties, lack of infrastructure, and generalized “security concerns” (which the Court subsequently rejected as invalid excuses for denying constitutional rights).

The Court noted chronic overcrowding in Indian prisons, operating at a national average of 120.8% capacity, with some states exceeding 150%.

Open Correctional Institutions (OCIs) are highlighted as the most humane, constitutionally compliant, and sustainable solution to decongestion.

Despite previous Supreme Court directions (in 2018), the Model Prison Manual (2016), and the Model Prisons Act (2023), states have shown widespread apathy in adopting and expanding OCIs.

The Supreme Court evaluated the functioning of the prison system through the lens of constitutional morality and reformative penology. The core issues of law considered by the Court were structured under the following heads:

• Whether the under-utilization of existing Open Correctional Institutions (OCIs) and their complete absence in several States/UTs violate the fundamental right to life, dignity, and rehabilitative justice under Article 21 of the Constitution.
• Whether the systemic exclusion of women prisoners from OCIs or the failure to transfer eligible women to such facilities on generalised security grounds constitutes gender discrimination violative of Articles 14, 15(1), 15(3), and 21.
• Whether the imposition of rigid, prolonged incarceration periods as a precondition for transfer to OCIs, coupled with their operation as mere labour camps without modern vocational training, frustrates the constitutional objective of modern reformative penology.
• Whether the vast disparities and lack of uniformity in OCI management across States (regarding wages, healthcare, family integration, and disciplinary actions) necessitate the formulation of Common Minimum Standards to prevent arbitrary and unequal treatment of prisoners.
• As data establishes that OCIs are “not merely a humane and rehabilitative alternative but also a financially rational correctional strategy,” whether the “massive cost differentials... make a strong constitutional and policy case for the systematic expansion of open correctional infrastructure across the country,” requiring States to “take proactive and time-bound steps to expand open correctional infrastructure.”

Based on empirical data collected by the Amicus Curiae and NALSA:

• Drastic Under-utilization: Existing OCIs are drastically under-utilized (occupancy as low as 6% in Delhi, 15% in HP/Uttarakhand). Several states and UTs possess zero OCI facilities.
• Gender Discrimination: Women prisoners are overwhelmingly excluded from OCIs. Several states explicitly bar women from OCIs. The Court ruled this as blatant gender discrimination violative of Articles 14, 15, and 21, rejecting security concerns as a valid excuse.
• Outdated Avenues: Prisoners often wait 4 to 21 years to become eligible for OCIs. Many OCIs function merely as agricultural labour camps rather than genuine rehabilitative centers offering modern vocational training, education, and family integration.
• Lack of Uniformity: There are vast disparities in wages, healthcare, family visitations, and disciplinary measures across different states.

To transform the theoretical constitutional mandate into an enforceable reality, the Supreme Court issued a comprehensive, multi-tiered set of directions under six distinct heads, binding upon the Union, States, and UTs:

The Court firmly established that prison reform is not executive benevolence but a constitutional obligation.

By the earlier order, the Court required all States and Union Territories to extend the L. Muruganantham directions to their prison systems. It also directed the creation of a robust, independent, and accessible grievance redressal mechanism for prisoners with disabilities. The Court further required meaningful inclusive education in prisons, application of Section 89 of the RPwD Act, 2016 to prison establishments, a structured mechanism for assistive devices and support equipment, and enhanced visitation rights for prisoners with benchmark disabilities.

The Court had also required all States and Union Territories to file comprehensive compliance reports within four months. Those reports were meant to show the measures taken, the progress achieved, and the modalities adopted for implementation

When the matter was heard on 8 April 2026, the Court noted that only 12 States and Union Territories had filed compliance affidavits so far. After hearing the parties, the Court concluded that the issues would be better addressed by the High-Powered Committee constituted in Suhas Chakma v. Union of India. The Court considered that committee better suited to examine the matter holistically, because it already dealt with systemic issues relating to open correctional institutions and prison reform

The Court transferred the subject matter into the ongoing work of the High-Powered Committee and expanded its remit. The Secretary, Department of Empowerment of Persons with Disabilities, Union of India, or a nominee not below the rank of Additional Secretary, was directed to actively participate in the committee proceedings. Similar participation was required from the Secretaries of Social Justice/Social Welfare departments of all States and Union Territories.

The States and Union Territories were directed to place their compliance affidavits before the High-Powered Committee within six weeks.The petitioners and intervenors were allowed to participate and submit representations. The Committee was empowered to ensure compliance with both L. Muruganantham and the Court’s earlier order in this case, and to issue necessary directions to concerned departments.

The Committee was also asked to prepare a comprehensive action plan for assistive devices, mobility aids, and support equipment for prisoners with disabilities, including standards, procurement, maintenance protocols, and security safeguards. It could seek help from expert institutions, specialised bodies, civil society organisations, and domain experts, with expenses to be borne by the Ministry of Social Justice and Empowerment as directed by the Committee. The Committee was asked to submit a consolidated status report within about four months, and the matter was listed again for 1 September 2026 along with Suhas Chakma.