Answer

Introduction

Caste-based discrimination in Indian prisons remains a profound constitutional challenge, where the hierarchy of the “outside world” is reproduced within the barracks. Despite the abolition of untouchability, several State Prison Manuals historically institutionalized labor and segregation based on birth, violating the foundational principles of dignity and equality.

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Historical Context and Colonial Roots

• Criminal Tribes Act: Colonial laws branded specific communities as “hereditary criminals,” leading to systemic surveillance and discriminatory confinement practices that persist in psychological biases.
  Eg: The Criminal Tribes Act of 1871 institutionalized the notion of “criminality by birth,” impacting Denotified Tribes even today.
• Colonial Manual Framing: British administrators codified local caste prejudices into Prison Manuals to maintain social order and prevent “upper-caste” rebellion within jails.
  Eg: The Prisons Act of 1894 allowed for “local customs” to dictate internal management, effectively shielding caste-based segregation.
• Hierarchical Labor Allocation: Manuals traditionally assigned “purity-based” tasks like cooking to dominant castes and “polluting” tasks like scavenging to marginalized communities. 
• Spatial Segregation Practices: Colonial-era infrastructure often allowed for the segregation of prisoners into different wards based on their perceived social status or “habits.” 
• Legacy of Purity: The British policy of “non-interference” in native religious practices meant that caste-bound dietary and sanitation rules were strictly enforced in prisons. 
• Administrative Inertia: After 1947, many states simply adopted colonial manuals without purging discriminatory clauses, leading to decades of unconstitutional practices. 

Supreme Court Intervention: Sukanya Shantha vs Union of India (2024)

• Striking Down Rules: The Court declared all caste-based labor division and segregation clauses in State Prison Manuals as unconstitutional and void. 
• Right to Dignity: It ruled that “caste-based discrimination” is a violation of the Right to Life under Article 21 and the right to equality.
  Eg: Chief Justice DY Chandrachud noted that “distribution of work based on caste” is a form of untouchability prohibited under Article 17.
• Barring Forced Labor: The Court emphasized that forcing marginalized castes into “menial” cleaning work constitutes “Begar” or forced labor under Article 23. 
• Prohibiting Caste Columns: The Court directed that the “caste column” in prisoner registers should be deleted to prevent profiling by jail authorities.
  Eg: States were ordered to revise the Prison Admission Registers to remove any reference to the prisoner’s caste.
• Directing Manual Overhaul: The SC mandated the Union Government to incorporate changes into the Model Prison Manual, 2016, and urged states to follow suit. 
• Suo Motu Monitoring: The Court reserved the right to monitor the progress of these reforms to ensure that “de facto” discrimination does not continue.
  Eg: The judgment highlighted that “customary practices” cannot override the constitutional mandate of an egalitarian society.

Conclusion

The Sukanya Shantha judgment marks a watershed moment in decolonizing the Indian carceral system. By dismantling the “legal architecture of caste” within prisons, the Supreme Court has moved toward transforming jails from sites of social reproduction into institutions of genuine rehabilitation. True reform will now depend on the sensitivity of jail staff and rigorous administrative oversight to ensure that the “caste shadow” is finally banished from the barracks.

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