Rudul Sah vs State of Bihar, (1983) 4 SCC 141

Rudul Sah vs State of Bihar established the Supreme Court’s authority to grant monetary compensation for the infringement of fundamental rights. This case is particularly significant as it emerged from a writ petition under Article 32 of the Indian Constitution, focusing on the illegal detention and subsequent ancillary relief for Rudul Sah.

Background of Rudul Sah vs State of Bihar

Arrest and Acquittal: Rudul Sah was arrested in 1953 on charges of murdering his wife. However, on June 3, 1968, the Muzaffarpur Sessions Court acquitted him, releasing him from all charges. Despite the acquittal, Sah remained incarcerated until October 16, 1982, enduring fourteen years of imprisonment without any proper legal cause.

Writ Petition: On November 22, 1982, Rudul Sah filed a writ petition of habeas corpus in the Supreme Court. This petition sought his release from prison on the grounds of false imprisonment, which violated his constitutional freedoms. Additionally, he sought ancillary reliefs including ex-gratia payment for his rehabilitation, reimbursement for medical treatment incurred during his detention and compensation for his illegal imprisonment even after being acquitted by the due process of law.

State’s Response: By the time the case was presented before the Supreme Court in November 1982, Rudul Sah had already been released from prison in October of the same year. Consequently, the Court focused on the ancillary reliefs sought by Sah. The Court issued a show-cause notice to the State, demanding an explanation for the delay in releasing Sah. The State’s response was delayed by over four months. When the response was finally submitted, it came in the form of an affidavit from the jailor of Muzaffarpur Central Jail, Shri Alakh Deo Singh, presenting two reasons for Sah’s prolonged detention:

1. Despite the acquittal, the Additional Sessions Judge, Muzaffarpur, had ordered that Sah be detained in prison until further orders from the State Government or the Inspector General of Prisons, Bihar.
2. Sah was allegedly of unsound mind and deemed incompetent to stand trial when the aforementioned order was issued.

The State claimed that following these procedures, Sah was detained and the information regarding his detention was communicated to the Law Department of the Muzaffarpur Central Jail through the Muzaffarpur District Magistrate. It was not until 1977 that a civil surgeon declared Sah to be of sound mind, which was communicated to the Muzaffarpur Central Jail. Despite this declaration, Sah remained incarcerated until October 1982.

Issues Before the Court

The Supreme Court in Rudul Sah vs State of Bihar was presented with two primary issues:

1. Whether the Court can grant monetary compensation for the infringement of fundamental rights under Article 32 of the Constitution.
2. Whether the scope of Article 21 includes the right to compensation for the violation of the right to personal liberty.

Contentions of the Parties

Petitioner’s Submissions

The counsel for Rudul Sah argued that his unlawful imprisonment for fourteen years, despite his acquittal in 1968, violated his fundamental right to life and personal liberty under Article 21 of the Constitution. They presented four prayers for relief in the petition:

1. Release from unlawful imprisonment (this became redundant after Sah’s release in October 1982).
2. State-funded or reimbursed medical treatment for Sah.
3. Compensation for Sah’s rehabilitation.
4. Compensation for the fourteen years of illegal detention after his acquittal.

The Court primarily focused on the latter three prayers, as the first prayer had become moot following Sah’s release.

Respondents’ Submissions

The State’s counsel, primarily through the affidavit submitted by Shri Alakh Deo Singh, made the following contentions:

1. Sah’s detention was ordered by the Additional Sessions Judge, Muzaffarpur, until further instructions from the State Government or the Inspector General of Prisons, Bihar.
2. Sah was of unsound mind during the trial, making him incompetent to stand trial.
3. Sah was treated according to the provisions of the Jail Manual of Bihar.
4. Sah was released in compliance with a letter issued by the Law Department of the Muzaffarpur Central Jail once he was declared of sound mind.

Based on these submissions, the respondents argued that there was no negligence on their part and that they acted in accordance with the orders issued by the District Magistrate, Muzaffarpur.

Rudul Sah vs State of Bihar Judgement

Ratio Decidendi: The Supreme Court in Rudul Sah vs State of Bihar observed that Sah’s fourteen-year imprisonment, despite his acquittal, was unlawful and unjustified. The Court highlighted that Article 32 grants the Supreme Court remedial powers to protect and enforce the fundamental rights enshrined in the Constitution of India. Consequently, the Court can grant monetary compensation for the infringement of fundamental rights.

The Court emphasised that the right to compensation is important for upholding the guarantee of the right to life and personal liberty under Article 21. The claim for compensation is a right for every aggrieved individual whose rights are infringed. If the State violates fundamental rights, it is liable to compensate the victim. Denying such a right would be against public interest and civilian rights.

The Court held that even if Sah was of unsound mind during the trial, his prolonged detention without proper legal procedure was still unlawful. The State’s actions were unjustified and lacked factual support.

Supreme Court’s Holdings: In light of the circumstances, the Supreme Court in Rudul Sah vs State of Bihar allowed the petition under Article 32 and ordered the Government of Bihar to pay Sah Rs. 30,000 as interim compensation, in addition to Rs. 5,000 already paid. The compensation was to be paid within two weeks of the judgement date.

The Court further held that Sah was not barred from pursuing further legal action against the State and its officials for proper damages. Since Sah’s imprisonment was deemed unlawful, he had the right to seek damages under tort for false imprisonment, thus triggering a civil cause of action as well.

Additionally, the Court in Rudul Sah vs State of Bihar advised the State to re-examine the prison administration of Bihar to rectify any mistakes that may have caused injustice to prisoners. The Supreme Court directed the High Court of Patna to assist in releasing prisoners unlawfully detained, like Sah. The directions included collecting statistical data on unlawful detentions in Bihar’s state jails from the Home Department and providing a detailed statement from all jails in Bihar disclosing the number of prisoners detained for over ten years.

Once these directions were implemented, the High Court of Patna would be better positioned to help prisoners in unlawful detentions. The Supreme Court also directed the High Court to ask the State government of Bihar to compensate these prisoners for the injustice caused and take appropriate steps for their rehabilitation.

Significance of Rudul Sah vs State of Bihar

Rudul Sah’s case is a landmark judgement in Indian constitutional law. It established the Supreme Court’s authority to grant monetary compensation for the violation of fundamental rights, a significant development in state liability jurisprudence. This case underscored the importance of holding the State accountable for the unlawful actions of its officials and ensuring that victims of such actions receive adequate compensation.

The judgement also expanded the scope of Article 21 to include the right to compensation for the violation of the right to personal liberty. This broadened interpretation of Article 21 paved the way for compensatory relief in numerous subsequent cases, extending the protection and enforcement of fundamental rights beyond mere declaratory judgements to actual financial redress for victims.

Following this case, the Supreme Court awarded compensation in several other cases, initially focusing on life and liberty rights, particularly in cases of illegal detention and unlawful deaths. The scope of compensation under Article 21 further expanded to include economic and social rights violations. For instance, in Paschim Banga Khet Samity v. State of West Bengal (1996 SCC(4)37), the Supreme Court granted compensation by linking the right to life with the right to health, referencing the Rudul Sah case.

Rudul Sah vs State of Bihar Case Summary

Rudul Sah v. State of Bihar (1983) is a landmark Supreme Court case in India. Rudul Sah was arrested in 1953 for allegedly murdering his wife and acquitted in 1968 but was unlawfully detained until 1982. Sah filed a writ petition under Article 32, seeking release, rehabilitation and compensation.

The Court ruled that his prolonged detention violated Article 21 (right to life and personal liberty) and awarded him interim compensation of Rs. 30,000, marking the first instance of monetary compensation for a fundamental rights violation in India. The judgement emphasised the State’s accountability and expanded the scope of Article 21 to include the right to compensation for unlawful detention.