Latest JudgementConstitution of India

Prema Devi v. State of U.P. Thru. its Prin. Secy. Home Deptt. Lko. and 5 others, 2026

It upholds Supreme Court precedents emphasizing remedy for deprivation of life or liberty as a constitutional obligation.

Allahabad High Court·20 February 2026

Constitution of India

Court

Allahabad High Court

Date of Decision

20 February 2026

Judges

Justice Shekhar B. Saraf and Justice Manjive Shukla

Citation

Acts / Provisions

Section 13(1)(ia), Hindu Marriage Act, 1955

Section 25, Hindu Marriage Act, 1955

Facts of the Case

The petitioner, Prema Devi, filed a writ petition under Article 226 seeking compensation for the unnatural death of her minor son while in District Prison Pilibhit.
The deceased, an undertrial in a POCSO case, died by suicide on 20 February 2024, hanging from the ventilator of a prison toilet.
The National Human Rights Commission (NHRC) had earlier recommended ₹3,00,000 as compensation, which was not paid due to inaction of the authorities.
The petitioner alleged that her son had been subjected to torture by police personnel in connection with illegal money demands, which ultimately resulted in his death.
The State argued that the death was a suicide, and there was no negligence, misconduct, or direct involvement on its part.
The Court observed that custodial deaths represent one of the most serious violations of fundamental rights, highlighting the State’s absolute duty to ensure life and dignity even for illegally detained individuals.

Whether the State is absolutely liable for the unnatural death of a prisoner in its custody, even if the death is a patently unnatural suicide?
Whether the right to life and human dignity under Article 21 extends to individuals who are illegally arrested or detained?
Whether monetary compensation is warranted in cases of custodial death, even in the absence of direct evidence of negligence or misconduct?
What systemic safeguards and guidelines should be mandated to prevent and address future custodial deaths?

The State is absolutely liable for unnatural custodial deaths, including suicide.
The right to life and human dignity under Article 21 extends to illegally detained prisoners.
Monetary compensation is a necessary remedy in custodial death cases.
Systemic reforms and mandatory procedural steps must be followed to ensure transparency, accountability, and protection of fundamental rights.

Strengthens the principle of strict liability of the State in custodial death cases.
Affirms that fundamental rights cannot be denied to undertrials or illegally detained prisoners.
Provides clear procedural guidelines for immediate notification, post mortem, judicial inquest, and compensation.
Ensures that monetary compensation is just, reasonable, and timely, enhancing victim-family protection.
Encourages States to frame standardized compensation policies, similar to multiplier method in MVA claims, creating predictability and fairness.
Upholds Supreme Court precedents emphasizing remedy for deprivation of life or liberty as a constitutional obligation.