Prisoners' right to adequate medical care supported custodial hospital treatment, while interim bail on medical grounds was refused.

A prisoner's right to life includes access to adequate medical treatment in custody. Where jail facilities cannot provide required specialised care and outside travel poses medical risk, the Court preferred custodial hospital treatment over interim bail. It found that the jail was providing medicines and some physiotherapy, but lacked specialised equipment needed for the inmate's spinal condition and post-epidural care. Interim bail on medical grounds was declined, while the inmate was directed to receive treatment at Safdarjung Hospital for a limited period and prison-health authorities were asked to improve medical facilities and monitoring.

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Issues: (i) Whether the applicant was entitled to interim bail on medical grounds for alleged inadequacy of prison medical facilities and post-epidural care. (ii) What relief and directions were warranted regarding the applicant's medical treatment and prison healthcare infrastructure.

Issue (i): Whether the applicant was entitled to interim bail on medical grounds for alleged inadequacy of prison medical facilities and post-epidural care.

Analysis: The applicant's medical records and the jail status report showed that specialised physiotherapy equipment such as IFT and ultrasonic machines was not available in Central Jail-07, while the applicant's spinal condition required ongoing post-epidural care. The applicant also could not safely be taken to outside OPD treatment because of the risk of aggravation from travel-related jerks and vibrations. At the same time, the material indicated that the jail authorities were providing medicines and some supervised physiotherapy, and that the issue was primarily the inability of the jail set-up to provide the required level of specialised care rather than a total denial of treatment.

Conclusion: The applicant was not granted interim bail on medical grounds.

Issue (ii): What relief and directions were warranted regarding the applicant's medical treatment and prison healthcare infrastructure.

Analysis: Prisoners retain the constitutional right to life and to adequate medical care, and the State remains responsible for ensuring reasonable and humane treatment in custody. Where the prison system cannot provide the necessary specialised care and outside travel is medically unsuitable, the appropriate course is to secure treatment at a referral hospital while keeping the inmate in custody. The Court also emphasised the need for adequate prison healthcare facilities and monitoring of medical equipment and supplies within the prison system.

Conclusion: The applicant was directed to be treated at Safdarjung Hospital for a limited period while remaining in custody, and further directions were issued to improve prison healthcare arrangements.

Final Conclusion: The applications were disposed of with custodial hospital treatment directions and broader directions to the prison and health authorities to ensure adequate inmate healthcare.

Ratio Decidendi: A prisoner's right to life includes a right to adequate medical treatment, and where jail facilities cannot provide required specialised care, the Court may direct treatment at a referral hospital while maintaining custody rather than grant interim bail.

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