Supreme Court Orders Compensation for Illegal Detention of Rudul Sah, Held 14 Years Post-Acquittal

landmark judgment affirms right to compensation under Article 21 and 32 of the Constitution, highlights grave prison administration failures. Illegal detention after acquittal entitles the petitioner to compensation directly from the Supreme Court under Article 32 of the Constitution, without the necessity of filing a separate suit for damages.

In a landmark judgment delivered on August 1, 1983, the Supreme Court of India, led by Chief Justice Y.V. Chandrachud, emphatically ruled in favor of Rudul Sah, who was illegally detained in a Bihar jail for over 14 years after being acquitted by the Sessions Court. The case, which exposed serious lapses in the prison administration of Bihar, culminated in the Court awarding interim compensation to the petitioner and underscored the State’s constitutional obligation to protect the fundamental right to liberty.

Rudul Sah was acquitted on June 3, 1968, by the Sessions Court in Muzaffarpur but was inexplicably held in custody until October 16, 1982. Upon filing a Habeas Corpus petition under Article 32 of the Constitution, Sah sought immediate release, medical treatment, rehabilitation expenses, and compensation for the unlawful incarceration.

Although the petitioner was eventually released, the Supreme Court insisted that the issue did not end there. The State Government of Bihar was directed to explain the prolonged detention, which it failed to do satisfactorily. The affidavit filed by the Jailor of Muzaffarpur Central Jail cited the petitioner’s supposed insanity as the justification for the continued detention, but the Court found this explanation inadequate and lacking any substantive medical evidence.

The Court highlighted that no medical records or proper treatment details were produced to validate claims of insanity, and the State’s failure to release Rudul Sah even after he was declared “normal” by a Civil Surgeon in 1977 was condemned as callous and insensitive. The Court strongly criticized the Bihar prison administration, pointing out systemic failures reminiscent of the infamous Bhagalpur blindings case, and called for urgent reforms including detailed statistical data on long-term illegal detentions.

Crucially, the Supreme Court recognized that the right to compensation for illegal detention flows from the fundamental right to life and liberty guaranteed under Article 21 of the Constitution. The Court held that merely releasing an unlawfully detained individual is insufficient; the State must also repair the damage caused. It asserted the Court’s jurisdiction under Article 32 to award compensation as a palliative remedy to uphold constitutional rights effectively.

Accordingly, the Court ordered the Government of Bihar to pay an interim compensation of Rs. 30,000 to Rudul Sah, in addition to Rs. 5,000 already paid, to be disbursed within two weeks. This order was independent of the State’s consent and did not preclude the petitioner from pursuing a full-fledged civil suit for damages.

The judgment is a powerful affirmation that the State’s violation of fundamental rights entails not only release from illegal detention but also monetary redress to prevent such gross injustices. It sends a clear message to all State authorities about their duty to uphold constitutional liberties and the consequences of administrative negligence.

Statutory provisions

Constitution of India, Article 21, Article 32

Rudul Sah v. State of Bihar, (SC) : Law Finder Doc Id # 103383