Summary
The Court upheld Maharashtra’s High Powered Committee classifications for temporary pandemic-related prison release. The scheme was an additional measure to reduce overcrowding, not a direction to release every prisoner or a substitute for ordinary bail law. Exclusion based on offence severity and special statutory bail restrictions was reasonable. Individual discrimination within the same eligible category remained reviewable, and representations for future modification could be made to the Committee.
Issues
- Whether offence-based exclusions from pandemic interim release violated equality.
- Whether the decongestion directions required compulsory or automatic release.
- What remedies remained for individual unequal treatment or changed prison conditions.
Provisions considered
- Article 14, Constitution of IndiaPermitted reasonable categorisation while preserving review of discrimination among similarly situated eligible prisoners. (¶¶ 8, 11, 14, 15)
Held
- The pandemic decongestion directions left State committees to assess prison occupancy, infection, infrastructure and local needs. They did not require compulsory release of every undertrial or convict regardless of offence and severity. (¶¶ 5, 7, 9, 10, 11)
- Reasonable classification is compatible with equality. Categorisation by punishment and separate treatment of serious economic offences or offences under special enactments with additional bail restrictions had a reasonable basis and was not arbitrary. (¶¶ 6, 8, 11, 12)
- Pandemic interim release was an additional health-protective benefit rather than an independent statutory entitlement to bail. Exclusion from that benefit did not prevent a prisoner from seeking ordinary bail according to law. (¶¶ 9, 11, 12)
- If existing releases and additional prisons proved insufficient, the Committee could reconsider its categories. Petitioners could furnish statistics and seek modification by representation; judicial alteration of the criteria required demonstrated extreme arbitrariness. (¶¶ 13, 14, 15)
- A prisoner denied a benefit available to similarly situated prisoners in the same category could seek limited judicial examination of that individual discrimination. (¶¶ 14, 15)
Result
Special leave petition dismissed with observations preserving representations to the Committee and individual discrimination claims. No order as to costs; pending application disposed of.