Supreme Court Awards Compensation for Illegal Detention
In a significant ruling, the Supreme Court of India has directed the State of Rajasthan to compensate a convict, Daudayal, with ₹11 lakh for being unlawfully detained for 24 days following a parole order. The decision was delivered by a bench comprising Justices Sanjay Karol and AG Masih in the case Daudayal v. State of Rajasthan.
Background of the Case
Daudayal was convicted by a trial court in 1988, receiving a four-year rigorous imprisonment sentence for a 1967 incident in Rajasthan involving charges of unlawful assembly, house trespass, and culpable homicide not amounting to murder. His conviction was upheld by the Rajasthan High Court in 2021, leading to his imprisonment.
In 2023, while serving his sentence, Daudayal sought permanent parole. After his request was denied by prison authorities, he appealed to the Rajasthan High Court. On November 5, 2024, a single-judge bench of the High Court approved his parole, subject to certain conditions. Despite meeting these conditions and having his sureties verified by November 13, 2024, Daudayal remained incarcerated.
Supreme Court’s Ruling
Daudayal subsequently petitioned the Supreme Court, seeking compensation for his wrongful detention. He argued that his continued imprisonment after parole violated his personal liberty under Article 21 of the Indian Constitution. The State of Rajasthan contended that the High Court’s order contradicted the Rajasthan Prisoners Release on Parole Rules, 1958, and attributed the delay to deliberations on whether to challenge the order.
The Supreme Court dismissed the State’s argument, emphasizing that a judicial directive for release must be honored unless stayed by a higher court. It underscored that the rights of a prisoner do not diminish during their sentence. The bench firmly stated, “The liberty of an individual is not a trivial matter. The State cannot continue curtailing the same in the face of a court order on account of its slow bureaucratic processes.”
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Consequently, the Court held that Daudayal’s continued detention amounted to illegal imprisonment, warranting compensation. The appeal was allowed, and Daudayal was awarded ₹11 lakh for the infringement of his personal liberty.
Legal Representation
Advocates Tushar Bathija, Rishabh Dheer, and Aishwarya Singh represented Daudayal, while advocates S Udaya Kumar Sagar, Kshitij Mittal, and Mayank Sharma appeared for the State of Rajasthan.
This ruling reinforces the judiciary’s stance on the sanctity of personal liberty and the obligation of the State to adhere to judicial orders promptly.
