ISSUE:
Whether the respondent, while in judicial custody, misused the production warrant to leave jail and address a political meeting?
Whether the respondent’s repeated violations of jail rules and continued influence over prison authorities warranted his transfer to a jail outside Bihar?
Whether the Supreme Court, in the absence of a specific statutory provision, could direct the transfer of the respondent to another jail under Article 142 of the Constitution?
RULE:
Judicial custody is not meant to be exploited for personal or political purposes. If an undertrial prisoner misuses a production warrant to engage in activities beyond its scope, it constitutes an abuse of the legal system.
A prisoner’s fundamental rights under Article 21 are subject to reasonable restrictions imposed by jail regulations. No individual, including a Member of Parliament, is entitled to special privileges that undermine prison discipline.
When a prisoner repeatedly violates legal and prison regulations, and jail authorities fail to enforce discipline, judicial intervention is necessary. Transferring such a prisoner to another jurisdiction is justified to uphold the rule of law and prevent further misuse of custody.
Article 142 empowers the Supreme Court to do complete justice in a given case, and in the absence of a specific statutory provision, it can order the transfer of a prisoner when required to maintain judicial integrity and ensure the fair administration of justice.