Rajeeb Kalita v. Union of India

The judgment in Rajeeb Kalita v. Union of India (2025) is a landmark decision of the Supreme Court of India that addresses a fundamental yet overlooked issue within the justice delivery system—the lack of adequate sanitation facilities in court premises.

The case highlights how the absence of clean, accessible, and inclusive toilet facilities affects not only public health but also the dignity of individuals who engage with the judicial system. It brings into focus the constitutional mandate under Article 21, which guarantees the right to life and personal liberty, including the right to live with dignity.

By examining sanitation through the lens of constitutional rights, the Court expanded the understanding of access to justice, making it clear that basic infrastructure plays a crucial role in ensuring fairness, dignity, and equality within legal institutions.

Facts of Rajeeb Kalita v. Union of India Case

The case originated from a Public Interest Litigation filed by an advocate, Rajeeb Kalita, who highlighted the poor and inadequate sanitation facilities in court premises, particularly in the State of Assam.

The petition pointed out that many court complexes lacked basic toilet facilities. In several instances, toilets were either unavailable, non-functional, or in unhygienic conditions. This created serious difficulties for judges, advocates, litigants, and court staff, all of whom spend considerable time within court premises.

Recognising the seriousness of the issue, the Supreme Court took cognisance of the matter and extended its scope beyond a single State. The Court directed High Courts across the country to submit detailed reports regarding the availability, accessibility, and condition of toilet facilities in court premises.

A report prepared by the Centre for Research & Planning of the Supreme Court revealed alarming conditions. Several High Courts reported the absence of adequate toilet facilities in district courts. A significant percentage of court premises lacked separate toilets for women. Many existing toilets were found to be dysfunctional, lacking basic amenities such as water supply and proper maintenance.

These findings established that the issue was not isolated but systemic, affecting the judicial infrastructure across the country.

Issues Raised

The Rajeeb Kalita v. Union of India case raised important constitutional and institutional issues:

• Whether the absence of adequate sanitation facilities in court premises violates the right to life and dignity under Article 21 of the Constitution of India.
• Whether the State has a constitutional obligation to ensure proper sanitation facilities in public institutions, including courts.
• Whether inadequate infrastructure in courts creates barriers to access to justice.

Petitioner’s Arguments

The petitioner presented detailed arguments emphasising the constitutional importance of sanitation:

• Right to Life Includes Sanitation: It was argued that the right to life under Article 21 includes the right to live with dignity. Access to basic necessities such as sanitation is essential for maintaining human dignity. The absence of toilets in court premises directly infringes upon this right.
• Public Health and Constitutional Duties: The petitioner referred to Article 47, which places a duty on the State to improve public health, and Article 48A, which mandates environmental protection. Sanitation was presented as a key element of both public health and environmental welfare.
• Government Initiatives and Standards: Reference was made to national initiatives such as the Swachh Bharat Mission, which promotes sanitation infrastructure across the country. International standards, including those recognised by the World Health Organization, were also cited to emphasise the importance of sanitation.
• Need for Facilities in Courts: The petitioner highlighted that while sanitation facilities are provided in other public places, courts have been neglected. Given the number of people who access courts daily, the lack of toilets renders the right under Article 21 ineffective in practice.

Observations of the Supreme Court in Rajeeb Kalita v. Union of India

The Supreme Court in Rajeeb Kalita v. Union of India made significant observations regarding the importance of sanitation:

• Sanitation as a Fundamental Right: The Court recognised that access to proper sanitation is an integral part of the right to life under Article 21. A dignified life requires a safe and hygienic environment.
• State’s Duty to Ensure Public Health: The Court emphasised that the State has a constitutional obligation under the Directive Principles of State Policy to improve public health and living conditions. This obligation extends to ensuring sanitation facilities in public institutions.
• Access to Justice and Infrastructure: The Court observed that access to justice is not limited to legal rights alone. It also includes the availability of basic amenities that allow individuals to participate in the judicial process with dignity.
• Concern over District Courts: The Court expressed concern over the lack of facilities in district courts, especially in rural areas. Even judges in certain locations were found to lack access to proper washroom facilities, which reflects poorly on the judicial system.
• Need for Immediate Action: The Court stressed that the issue requires urgent and effective intervention and cannot be treated as a minor administrative concern.

Key Case Laws Referred

The Court relied on several precedents to support its reasoning:

• Vincent Panikurlangara v. Union of India: This case established that the State has a responsibility to ensure conditions conducive to good health, which is essential for human dignity.
• In Re: Amarnath Shrine Case: It was held that the right to life includes the right to a healthy and hygienic environment.
• Common Cause v. Union of India: The Court reiterated that the right to life includes the right to live with dignity, beyond mere survival.
• Consumer Education and Research Centre v. Union of India: The case recognised health as an integral part of the right to life and emphasised the State’s responsibility in ensuring it.
• State of M.P. v. Kedia Leather & Liquor Ltd.: The Court held that environmental pollution and lack of hygiene directly affect the right to life.
• National Legal Services Authority v. Union of India: The Court recognised the need for inclusive facilities, particularly for transgender individuals, to prevent discrimination and ensure safety.
• Francis Coralie Mullin v. Administrator, Union Territory of Delhi: It was held that the right to life includes the right to live with human dignity.
• Bandhua Mukti Morcha v. Union of India: The Court linked degrading living and working conditions with violations of fundamental rights.
• Municipal Council, Ratlam v. Vardichan: The Court compelled authorities to provide sanitation facilities, recognising it as a public duty.
• Virender Gaur v. State of Haryana: It was held that a hygienic environment is essential for enjoying the right to life.

These precedents collectively established that sanitation, health, and dignity are interconnected constitutional values.

Global Practices Considered

The Court also examined sanitation practices in other countries to understand global standards:

• Germany’s “Changing Places” initiative focuses on accessibility for persons with disabilities.
• Canada’s “Pop-Up Public Toilet” initiative promotes inclusive and innovative sanitation solutions.
• Japan has developed all-gender universal toilets catering to diverse needs.
• Singapore emphasises cleanliness and maintenance of public restrooms.
• The United Kingdom promotes improved restroom standards through institutional efforts.
• Australia provides a National Toilet Map to ensure accessibility to sanitation facilities.

These examples demonstrated that sanitation is treated as a priority globally and highlighted the need for similar measures in India.

Directives Issued by the Court in Rajeeb Kalita v. Union of India

The Supreme Court in Rajeeb Kalita v. Union of India issued comprehensive directions to address the issue:

• Separate and Inclusive Toilet Facilities: All court premises must provide separate toilets for men, women, persons with disabilities, and transgender individuals. This ensures inclusivity and safety for all users.
• Accessibility and Identification: Toilet facilities must be clearly identifiable and easily accessible to judges, advocates, litigants, and staff.
• Formation of Monitoring Committees: Each High Court must constitute a committee to oversee the implementation of sanitation measures. These committees are responsible for monitoring progress and ensuring compliance.
• Assessment and Surveys: Committees must conduct detailed surveys to identify gaps in infrastructure and recommend necessary improvements.
• Maintenance and Functionality: Regular maintenance of toilets must be ensured, including proper water supply, cleanliness, and functionality of facilities.
• Grievance Redressal Mechanism: A system must be established for reporting and addressing issues related to sanitation facilities.
• Allocation of Funds: State Governments and Union Territories must allocate dedicated funds for construction and maintenance of sanitation infrastructure.

These directives aimed at bringing structural reforms in court infrastructure across the country.

Ratio Decidendi

The central legal principle laid down in Rajeeb Kalita v. Union of India case is that access to adequate and hygienic sanitation facilities is an essential component of the right to life and dignity under Article 21 of the Constitution of India.

The State has a constitutional obligation to ensure that public institutions, including courts, provide such facilities. The absence of sanitation infrastructure creates barriers to access to justice and violates fundamental rights.

Rajeeb Kalita v. Union of India Judgment 

The Supreme Court in Rajeeb Kalita v. Union of India held that access to proper sanitation facilities in court premises is an integral part of the right to life and dignity under Article 21 of the Constitution of India. The Court observed that the absence of clean, functional, and inclusive toilets creates barriers to access to justice and undermines the dignity of judges, advocates, litigants, and court staff.

Accordingly, the Court issued directions to all High Courts to ensure the construction and maintenance of separate and accessible toilet facilities for men, women, persons with disabilities, and transgender individuals. It also mandated the formation of monitoring committees, regular maintenance mechanisms, and allocation of funds to ensure effective implementation of sanitation standards.

Conclusion

The judgment in Rajeeb Kalita v. Union of India marks an important step in recognising the role of sanitation in ensuring dignity and access to justice. By addressing the lack of toilet facilities in courts, the Supreme Court has brought attention to a critical issue affecting the daily functioning of the judicial system.

The case underscores that justice is not only about legal rights and procedures but also about the conditions in which individuals engage with the system. Ensuring clean, accessible, and inclusive sanitation facilities is essential for upholding the dignity of all stakeholders and maintaining the credibility of the judicial system.