The Orissa High Court has underscored the constitutional significance of the right to health, ruling that it is an integral component of the right to life under Article 21 of the Constitution of India. In a landmark judgment, the court awarded ₹20 lakh in compensation to the wife of an undertrial prisoner who died in custody due to medical negligence by jail authorities, highlighting systemic lapses in custodial healthcare.

Justice Biraja Prasanna Satapathy delivered the judgment on Tuesday in response to a petition filed by Sabita Nishank, the widow of the deceased, who sought ₹50 lakh as compensation for her husband’s death. The court concluded that the claims of negligence were “well proved,” noting that prison authorities failed to provide adequate medical attention despite being aware that the undertrial was a chronic diabetic patient.

The deceased, who had been working as a Panchayat Executive Officer in Opega and Pansora gram panchayats, was remanded to judicial custody on September 20, 2016, in connection with a case involving charges under Sections 409 (criminal breach of trust by public servant), 120(B) (criminal conspiracy), and 34 (acts done by multiple people) of the erstwhile Indian Penal Code. The petitioner’s husband had been diagnosed with chronic diabetes in 2008, a condition that was well documented and known to the jail authorities prior to and during his incarceration.

According to the petition, the undertrial prisoner’s health deteriorated during his custody because he was not provided with proper medical treatment for his diabetic condition. Despite repeated complaints by the petitioner and her intervention through official channels, jail authorities delayed taking adequate steps to ensure proper medical care. Only after Sabita Nishank moved an application before the Judicial Magistrate First Class (JMFC) in Pipili on January 21, 2017, did the prison authorities act.

On January 24, 2017, the superintendent of Nimapara Sub-Jail wrote to the JMFC requesting the undertrial’s transfer to the District Headquarters Hospital in Puri to receive better medical treatment. By the time he was transferred on January 25, his health had already deteriorated severely. He was subsequently referred to the SCB Medical College and Hospital in Cuttack on the same day, but tragically, he passed away the following day, January 26, 2017, while undergoing treatment.

In its judgment, the Orissa High Court observed that the delay and inaction by jail authorities reflected “serious laxity” and constituted a violation of the prisoner’s fundamental rights. Justice Satapathy emphasized that prisoners are entirely dependent on the state for medical care due to their deprivation of personal liberty. The custodial death due to medical negligence, therefore, amounted to a significant infringement of constitutional guarantees, warranting appropriate redress and compensation.

The court also reflected on the broader legal and human rights implications of the case. By explicitly linking the right to health with the right to life, the judgment reinforces the principle that custodial authorities carry an enhanced responsibility toward the well-being of prisoners. Negligence in providing timely and adequate medical care not only endangers the lives of undertrials but also undermines the fundamental protections afforded under the Constitution.

Justice Satapathy noted that by the time directions were issued to transfer the undertrial for proper medical care, it was “too late” to prevent his demise. The judgment underscores the accountability of prison authorities in ensuring timely healthcare interventions for inmates, particularly those with chronic illnesses, and sets a precedent for compensation claims in cases of custodial deaths arising from medical negligence.

The Orissa High Court’s decision carries important implications for prison administration, highlighting the need for proactive medical oversight and infrastructure that can respond swiftly to emergencies. Chronic conditions like diabetes, if left untreated in custodial settings, can escalate rapidly, as was tragically demonstrated in this case. The judgment may serve as a catalyst for systemic reforms aimed at ensuring adequate medical facilities, monitoring, and accountability mechanisms in prisons across the state.

The case also illustrates the crucial role of family members and legal advocates in bringing attention to lapses in custodial care. Sabita Nishank’s persistence in pursuing the matter through judicial channels prompted a formal acknowledgment of the negligence and ultimately led to the award of compensation. This highlights the importance of legal recourse in safeguarding the rights of undertrials and prisoners, who are among the most vulnerable populations in the criminal justice system.

The court’s ruling comes at a time when custodial deaths and inadequate healthcare in prisons have been a matter of public concern nationwide. It reinforces the principle that imprisonment does not strip individuals of their fundamental rights, including the right to life and the right to health. By awarding ₹20 lakh in compensation, the court not only provided relief to the aggrieved family but also sent a strong message about the state’s obligations toward prisoners’ health and well-being.

Moreover, the judgment emphasizes that medical negligence in custodial settings is not a mere administrative lapse; it is a constitutional violation that warrants accountability and remediation. The decision strengthens the jurisprudence linking custodial responsibility with the fundamental rights guaranteed under the Indian Constitution, particularly Articles 21 and 39(e) of the Directive Principles, which relate to the health and well-being of citizens.

The Orissa High Court’s ruling is expected to influence prison policies, compelling authorities to implement stricter protocols for monitoring inmates with chronic illnesses, ensuring timely medical interventions, and maintaining adequate healthcare infrastructure within correctional facilities. It also underscores the judiciary’s critical role in enforcing constitutional protections and holding state authorities accountable for lapses that result in preventable deaths.

In conclusion, the case represents a significant affirmation of prisoners’ rights in India, emphasizing that the right to health is inseparable from the right to life. By awarding ₹20 lakh to the widow of the deceased undertrial, the Orissa High Court has reinforced the principle that custodial authorities are obligated to provide adequate and timely medical care to inmates. The judgment serves as a reminder that deprivation of liberty does not equate to deprivation of fundamental rights, and it highlights the ongoing need for systemic reforms to prevent medical negligence and safeguard the health of prisoners across the country.

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