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Issues: (i) Whether routine handcuffing of undertrial prisoners, including classification-based handcuffing of "better class" prisoners, is constitutionally valid; (ii) Whether handcuffing may be imposed only as a last resort on the basis of individualised reasons, with judicial supervision and recorded justification.
Issue (i): Whether routine handcuffing of undertrial prisoners, including classification-based handcuffing of "better class" prisoners, is constitutionally valid.
Analysis: The constitutional guarantees of equality, personal liberty and human dignity forbid the routine use of irons on persons in custody. The legal framework under the prison and police rules cannot authorise a broad presumption that undertrials, or any class of undertrials, should be handcuffed merely because of the offence alleged, social status, or class designation. A classification that turns on wealth, education or social standing is arbitrary and irrational, and it has no legitimate nexus with the real security question, namely whether a particular prisoner is likely to escape or become violent.
Conclusion: Routine handcuffing and class-based handcuffing are unconstitutional and invalid, and the petitioner succeeds on this issue.
Issue (ii): Whether handcuffing may be imposed only as a last resort on the basis of individualised reasons, with judicial supervision and recorded justification.
Analysis: The lawful restraint of a prisoner in transit must be confined to exceptional cases where there is concrete material showing a real risk of escape, violence or similar necessity. Subjective apprehension, general allegations, or the mere seriousness of the charge are insufficient. The authority must record contemporaneous reasons, and the court before which the prisoner is produced must be informed so that the restraint is subject to judicial control. Less restrictive alternatives, such as additional escort, armed guard or protected transport, must be preferred where adequate.
Conclusion: Handcuffing is permissible only in rare cases of necessity, as a last resort, on recorded reasons and under judicial oversight.
Final Conclusion: The law was read down to make freedom from handcuffs the norm for prisoners in transit, with irons permitted only in exceptional cases justified by concrete necessity and controlled by the court.
Ratio Decidendi: Under Articles 14, 19 and 21, a prisoner in transit may not be handcuffed routinely or on the basis of class or offence alone; restraints are lawful only when strictly necessary to prevent escape or violence, supported by recorded reasons and judicial control.