Francis Coralie Mullin v. Union Territory of Delhi (1981)
AIR 1981 SC 746 — Article 21 means life with dignity. Detenue interview rights with family and lawyers affirmed.
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Article 21 is wide. It is not only about keeping a person alive. It includes a life with dignity and humane treatment. The Court said detenues must get reasonable interviews with their lawyer and family. Rules that make such meetings almost impossible are unfair and need correction.
- Does Article 21 cover dignity and humane conditions beyond mere survival?
- Does a preventively detained person have enforceable rights to meet family and lawyer?
- Article 21: Protection of life and personal liberty — interpreted to include living with dignity and humane treatment.
- Interview rules were too harsh; they blocked access to family and counsel.
- Article 21 includes dignity; restrictions must be humane and reasonable.
- Security and discipline justify limited interviews for detenues.
- Existing clauses were lawful and applied to all alike.
The Supreme Court ruled that the right to life includes the right to live with dignity. Detenues must get reasonable opportunities to meet lawyers and family. If under-trials can meet twice a week and convicts once a week, a detenue cannot be treated worse without strong reasons. The restrictive clauses needed to be relaxed to match humane standards.
- Article 21 covers dignity, humane treatment, and basic facilities needed for a meaningful life.
- Detenues have enforceable rights to meet lawyers and family, subject to reasonable prison rules.
- Prisons cannot impose harsher limits on detenues than on under-trials/convicts without good cause.
This case shapes modern Article 21 thinking. It guards dignity behind bars and ensures real access to family and legal help. It prevents prison rules from silently cutting basic human contact.
- Life with dignity is part of Article 21.
- Reasonable, regular interviews for detenues.
- Family and lawyer access cannot be illusory.
- Prison rules must be humane and non-arbitrary.
- Comparative standard: under-trial/convict interviews.
Mnemonic: “D-I-G”
- Dignity is part of life.
- Interviews with lawyer & family must be real.
- Guided by humane, reasonable prison rules.
| I | Issues |
|---|---|
| I | Scope of Article 21; detenue’s rights to meet counsel and family under prison rules. |
| R | Rules |
|---|---|
| R | Article 21 protects life with dignity; restrictions must be reasonable and humane. |
| A | Application |
|---|---|
| A | Comparing with interview rights of under-trials/convicts, the stricter limits on detenues were unjustified. |
| C | Conclusion |
|---|---|
| C | Interview restrictions must be eased; humane access to lawyer and family mandated. |
- Article 21
- Guarantees life and personal liberty; interpreted to include dignity and humane living.
- Detenue
- A person kept in preventive detention (before trial or punishment).
- COFEPOSA
- Conservation of Foreign Exchange and Prevention of Smuggling Activities Act.
- Interview Rights
- Reasonable meetings with lawyer and family under fair prison procedures.
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