Case Summary: Rudul Sah v. State of Bihar (1983)
Name of the Court: Supreme Court of India
Case No: Writ Petition (Criminal) No. 1387 of 1982
Date of Decision: 01-08-1983
Bench: Y.V. Chandrachud, C.J.; Ranganath Misra, J.; A.N. Sen, J.
Final Decision: Compensation Awarded; Recognition of Right to Compensation for Violation of Fundamental Rights
All Citations: AIR 1983 SC 1086; (1983) CriLJ 1644; (1983) 2 SCALE 103; (1983) 4 SCC 141; (1983) 3 SCR 508
[Judgment Source]
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Facts of the Case
The petitioner, Rudul Sah, was acquitted by the Court of Sessions, Muzaffarpur, Bihar, on June 3, 1968, but was illegally detained in jail for over 14 years until October 16, 1982.
He filed a Habeas Corpus petition under Article 32 seeking release, medical treatment, rehabilitation, and compensation.
The State offered no timely explanation, and its claim of his insanity was unsupported by medical evidence. The Supreme Court criticized the Bihar Prison Administration's negligence.
Law Points Raised
1. Whether the Supreme Court under Article 32 can award monetary compensation for violation of Fundamental Rights.
2. Scope of Article 21 – Right to life and personal liberty includes the right to compensation for unlawful detention.
3. Accountability of the State for illegal acts committed by its officers.
Acts / Provisions / Articles Referred
- Constitution of India, 1950 – Article 21, Article 32
- Criminal Procedure Code – Provisions regarding trial of persons of unsound mind
Judgements Referred
This case established a precedent for awarding compensation in writ jurisdiction for violation of Fundamental Rights.
Obiter Dicta
The Court condemned administrative apathy and emphasized the duty of the State to uphold prisoners’ rights and prevent unlawful detention.
Ratio Decidendi
The Supreme Court held that monetary compensation can be awarded under Article 32 as a remedy for violation of Fundamental Rights, especially Article 21, when illegal detention is established beyond doubt.
Final Ruling
The Court directed the State of Bihar to pay Rs. 30,000 as interim compensation to Rudul Sah, recognizing the right to compensation as part of the enforcement of Article 21.
Relevant Paragraph Numbers
Paras: 8, 9, 10 – Recognition of compensation as a remedy for violation of Fundamental Rights under Article 32.
Summary
This landmark judgment in Rudul Sah v. State of Bihar (1983) expanded the scope of Article 32 by recognizing the Supreme Court’s power to award compensation for violation of Fundamental Rights, setting a precedent for future human rights cases in India.
[Judgment Source]
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