Introduction 

The intersection of prisoners' fundamental rights and prison administration presents complex legal challenges in the Indian correctional system. Recent judicial developments, particularly the Mumbai Central Prison case involving an undertrial prisoner. Prisoners' demand for Jain food have brought renewed attention to the delicate balance between religious freedom and prison discipline. The right to food, recognized as integral to human dignity under both domestic and international human rights frameworks, assumes particular significance in the context of incarcerated individuals who retain fundamental rights despite the curtailment of their liberty. 

What was the Background of the Case? 

• In March 2025, the Enforcement Directorate arrested Mumbai resident Prisoner in connection with a money laundering investigation involving misuse of bank accounts of Malegaon residents. Shah, a follower of Jainism, approached the special court designated under the Prevention of Money Laundering Act (PMLA) in May 2025, stating that he had followed a strict Jain diet throughout his life based on religious requirements.  
• He pleaded that the food served in Mumbai Central Prison did not meet his dietary preferences and was affecting his health, causing substantial weight loss. 
• The court initially allowed his plea on 14th May 2025, directing the prison superintendent to provide Jain food, but Shah approached the court again in June, claiming non-compliance and that he was surviving only on chapatis.  
• The prison superintendent informed the court that Shah was being provided dal and sabzi without onion, garlic, and potatoes as per religious requirements. However, Shah continued to complain that the jail had stopped providing requisite meals after initial compliance, prompting repeated court interventions and show-cause notices to the prison administration. 

What were the Court Observations? 

• The Mumbai special court observed that "as the accused is a follower of Jainism, he is entitled to get diet accepted by Jain religion" and directed the superintendent to provide him with Jain food.  
• This judicial recognition established the principle that genuine religious dietary requirements of prisoners warrant accommodation within the prison system.  
• The court's directive reflected a balance between acknowledging religious rights and practical prison administration. 
• Following non-compliance complaints, the court issued show-cause notices to Mumbai Central Prison, demonstrating judicial willingness to ensure enforcement of dietary accommodation orders through contempt proceedings. The repeated interventions indicate judicial concern for both the protection of prisoners' religious rights and the accountability of prison administration in implementing court orders. 
• The court's approach reflects recognition that religious accommodation is not merely a privilege, but a constitutional right that must be protected even within correctional facilities. 

What are the Legal Provisions? 

• Article 25 of the Constitution of India, 1950 (COI)guarantees freedom of religion, including the right to practice religious dietary customs, which extends to prisoners subject to reasonable restrictions for security and discipline.  
  • Prisoners retain fundamental rights except those specifically restricted by law for legitimate penological purposes. 
• The Supreme Court has consistently held that incarceration does not result in complete forfeiture of constitutional rights, and religious freedom remains protected even within prison walls. 
• The Model Prison Manual issued by the Ministry of Home Affairs permits special food arrangements for religious fasts while prohibiting kitchen management and cooking based on caste or religion in prisons.  
  • The manual establishes nutritional standards specifying that prisoners require 2,000-2,400 calories daily, with states permitted to adapt diet scales based on climatic conditions and local habits. 
  • This framework provides flexibility for regional variations while maintaining minimum nutritional standards. 
• The 1958 Allahabad High Court ruling in Lakshmi Narain v. The State (1958) established that "jails are not places where people can have their own choice of food," while subsequent judicial developments have recognized reasonable accommodation of genuine religious dietary requirements.  
• The Punjab and Haryana High Court in 2017 called for uniform policies on meals for prisoners fasting during Ramzan, while the 2022 rejection of Satyendra Jain's similar plea for Jain food illustrates the case-specific nature of judicial determinations and the requirement for genuine religious necessity rather than mere preference. 

Conclusion 

The legal landscape surrounding prisoners' dietary rights in India reflects ongoing tension between constitutional guarantees of religious freedom and practical constraints of prison administration. While the Constitution and judicial precedents establish clear principles protecting prisoners' fundamental rights, implementation of religious dietary accommodations remains challenging due to logistical, budgetary, and administrative constraints. The Mumbai Central Prison case demonstrates both judicial commitment to protecting religious rights and the need for better coordination between court orders and prison administration.