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Supreme Court Orders Rs 11 Lakh For Man Held 24 Days After High Court Parole Order

The bench ruled that officials may not delay a court‑ordered release to consider filing appeals, with the decision affirming monetary awards as a remedy for Article 21 violations.

Overview

  • A bench of Justices Sanjay Karol and Augustine George Masih held on May 29 that the State of Rajasthan must pay Rs 11 lakh to Daudayal for 24 days of unlawful custody after a High Court parole order was not implemented.
  • The Rajasthan High Court first directed his release on November 5, 2024 after he furnished a bond and two sureties and a Division Bench ordered immediate release on December 6, 2024, but prison authorities kept him detained while they considered administrative steps.
  • The Supreme Court rejected the State's argument that delay was justified by the Rajasthan Prisoners Release on Parole Rules, 1958 and said administrative deliberation over whether to file an appeal cannot lawfully extend detention once release conditions are verified.
  • The court relied on precedents such as Rudul Sah, Bhim Singh and Nilabati Behera to reconfirm that monetary compensation is an available public‑law remedy for violations of the constitutional right to life and personal liberty under Article 21.
  • The ruling highlights a gap between judicial orders and prison administration procedures and signals that states may face financial liability when bureaucratic delays prevent timely implementation of release directions.