RAJIV GANDHI NATIONAL UNIVERSITY OF LAW (RGNUL),

PATIALA

CRIMINOLOGY AND PENOLOGY

A STUDY OF PRISON REFORMS VIS-À-VIS RIGHT OF

PRISONERS

Submitted by: Submitted To:

Hitarth Dixit Dr. Ivneet Walia

Roll no.-19150 (Associate Professor of Law)

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 TABLE OF CONTENTS

I. ABSTRACT ..................................................................................................3

II. RESEARCH QUESTIONS.........................................................................3

III. CHAPTERISATION...................................................................................3

1. INTERNATIONALS OBLIGATIONS AND GUIDELINES .......................... 3

1.1. PRISON REFORMS IN INDIA- BRIEF BACKGROUND .......................... 4

2. RIGHTS OF PRISONERS ....................................................................................... 5

2.1. RIGHT TO LEGAL AID ...................................................................................... 6

2.2. RIGHT TO HEALTH ........................................................................................... 6

2.3. RIGHT TO A SPEEDY TRIAL........................................................................... 7

2.4. RIGHT AGAINST INHUMAN TREATMENT OF PRISONERS .............. 7

IV. UNDER TRIAL PRISONERS ...................................................................7

4.1. DEFINITIONS ....................................................................................................... 8

4.2. STATISTICAL ANALYSIS ................................................................................... 8

4.3. UNDER TRIALS OR CONVICTED ................................................................. 9

CRIMINALIZING EFFECT OF PRISON ............................................................... 9

HEALTH PROBLEMS ............................................................................................... 10

DRUG ABUSE ............................................................................................................. 10

V. PROBLEMS OF PRISON IN INDIA ...................................................... 10

VI. EDUCATIONAL REFORMS................................................................... 12

VII. CONCLUSION ......................................................................................... 13

VIII. REFERENCES.......................................................................................... 14
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 I. ABSTRACT

Prison changes have long been viewed as necessary in order to allow inmates to live in decent
circumstances while they serve their sentences. At different levels, a variety of stakeholders have
taken part in the advocacy of these reforms. Some critics of these measures have asserted that
they equate to turning jails into "holiday camps." It's interesting that no one had bothered to
inquire as to how the convicts facing trial felt about it. In addition, our effort aimed to show that
improving education is essential for reforming the jail system, but do we really care about
prisoner education? The analysis in this publication is descriptive. The majority of the secondary
research used to get the data for this work was examining reports and statistical analysis of data
provided on official government websites.

II. RESEARCH QUESTIONS

1) Do Prisons in India generates a difference between convicted and under trials criminals?
2) Educational reforms have any impact over prisoners?

III. CHAPTERISATION

1. INTERNATIONALS OBLIGATIONS AND GUIDELINES

The principal international instrument for the defence of prisoners' rights is the International
Covenant on Civil and Political Rights (ICCPR). Since India accepted the Covenant in 1979, it is
required to implement its provisions into national legislation and government policy. According
to the International Covenant on Economic, Social, and Cultural Rights (ICESR), prisoners are
entitled to the best possible physical and mental health conditions. In addition to their civil and
political rights, inmates are also entitled to the so-called second generation of economic and
social human rights as outlined in the ICESR. Five sections and 95 regulations make up the
previous United Nations Standard Minimum regulations for the Treatment of Prisoners, 1955.
The first section contains guidelines for general use. There must not be any "discrimination on

3
grounds of race, colour, sex, language, religion, political or other opinion, national or social
origin, property, birth or other status," according to this statement. In addition, there is a critical
requirement to respect the moral standards and religious beliefs of the community to which a
prisoner belongs. The standard regulations take into account the separation of the various
prisoner types. It suggests that males and women should be held in different facilities. Prisoners
who are awaiting trial must be kept apart from those who have been found guilty. It also supports
total segregation of those incarcerated for crimes committed under civil law from those for
crimes committed under criminal law. The UN's Minimum Standard Rule also makes it essential
to house young and child detainees apart from adult prisoners. Following UN guidelines include
the Body of Principles for the Protection of All Persons under Any Form of Detention or
Imprisonment (United Nations 1988) and the Basic Principles for the Treatment of Prisoners
(United Nations 1990).1

The general minimum regulations on jail infractions and punishment are fairly explicit. No
prisoner may be punished "without having been informed of the offences alleged against him/her
and given a proper opportunity of presenting his/her defence," according to the regulations. It
suggests that all "cruel, inhuman, or degrading punishments shall be completely prohibited as a
mode of punishment and disciplinary action" in the prisons. This includes physical punishment,
isolation in a dark cell, and other forms of punishment.

1.1. Prison Reforms in India- Brief Background

Mahaworker (2006) analysed the development of prisons in India and the following changes in
great depth. Below is a succinct overview of the same. The Minute by TB Macaulay in 1835 is
credited with creating the modern jail in India. An appointed body called the Prison Discipline
body turned up its findings in 1838. The committee rejected all requests for assistance and
improvements for the detainees and instead advocated for more stringent treatment. The
Macaulay Committee made suggestions between 1836 and 1838, and Central Prisons were built
starting in 1846. Therefore, British dominance is still evident in the way that prisons are
managed now in India. Its foundation is the idea that even the strongest criminal legislation won't

1
Bijalwan Anubhav, “Prison Reforms in India”, Criminal Law Review, 2018, Available at -
https://crlreview.in/prison-reforms
inindia/#:~:text=The%20Indian%20Jail%20Reforms%20Committee,a%20living%20wage%20on%20release.
(Accessed on –7 April 2023)

4
help a society much if there isn't an effective system in place for administering sanctions. Similar
suggestions were given by the Second Commission of Inquiry into Jail Management and
Discipline in 1864 as they were by the 1836 Committee. Additionally, this Commission provided
several specific recommendations about prisoner housing, dietary enhancements, clothes,
bedding, and medical attention.

In order to create a model prison manual, the Government of India established the All India jail
manual committee in 1957. In 1960, the committee turned in its final report. The proposals of Dr.
Reckless about prison improvements were likewise accepted by the eighth conference of
inspector generals of prisons in 1957. The paper offered strong arguments for developing a
consistent policy and cutting-edge procedures for managing jails, probation, after-care, juvenile
and remand facilities, and certified and reformatory schools. prisons and safe houses, the
repression of immoral commerce, etc. The report also suggested amendments in the Prison Act
1984 to provide a legal base for correctional work.

2. RIGHTS OF PRISONERS

In India, the discussion about prison reforms or the rights of prisoners is not entirely
acknowledged. In a modern democracy, prisons have been as reformative care-giving
institutions. On the contrary, reality differs as prisons have a lack of basic needs, food, medical
treatment, and cleanliness. Society’s understanding of the concept of prison is limited to the fear
of controlling crime and avoiding disturbance within the system. According to the Model Prison
Manual 2016, India is of the view that a sentence of imprisonment is only justifiable when it
ultimately leads to the protection of society. It could be achieved only when an offender after his
release is motivated enough to ensure a law-abiding and self-supporting life. The Mulla
Committee report established the rights of prisoners, declaring that, like other country citizens,
they have the right to dignity, the ability to communicate, access to the legal system, etc. In order
to establish consistent law that incorporates contemporary ideals about the reformation and
rehabilitation of criminals, the subject matter of jails and institutions was included to the
Concurrent List, 7th Schedule to the Constitution of India.

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2.1. Right to Legal Aid
The Constitution does not define the phrase "right to legal aid." Free Legal Aid was established
as one of the guiding principles of state policy under Article 39A by the 42nd Amendment Act of
1976.

The Supreme Court ruled in Madhav Hayawadan Rao Hosket v. State of Maharashtra that
Articles 21 and 39-A in conjunction with Articles 142 and 304 of the Cr.PC. require the
government to provide aid to those prosecuted. 2

Even though Article 39A is not enforceable by courts yet it is a direct reference of an article of
the Constitution. It states that the government has an obligation towards its citizens that no unjust
actions take place because of non-availability legal advice.

2.2. Right to Health

It states that prisoners have the "Right to fulfilment of basic minimum needs such as adequate
diet, health, medical care and treatment, access to clean and adequate drinking water, access to
clean and hygienic conditions of living accommodations, sanitation and personal hygiene,
adequate clothing, bedding and other equipment," which includes health under the heading "right
to basic minimum needs." "All accommodation provided for use of prisoners, particularly for
sleeping, will meet basic requirements of healthy living," the guideline adds under the subject of
"housing."

In Rasikbhai Ramsun Rana v. State of Gujarat, the Gujarat High Court ruled that because the
Central Prison in Vadodara lacked the jail escorts necessary to transport petitioners with serious
illnesses to hospitals, they were denied access to proper and prompt medical care. The court also
held the I.G. Prison and Additional Chief Secretary personally liable. 3

The Gujarat High Court directed the state government in a suo moto writ suit in 2005 to make
sure that all Central and District prisons had ICCUs, pathology labs, experienced physicians,
enough staff, including nurses, and the newest medical equipment for treatment.

2
M.H. Hoksot v. State of Maharashtra, 1978 3 SCC 544.
3
Rasikbhai Ramsun Rana vs. State of Gujarat, 1997 Cr LR (Guj) 442.

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In Sanjay V. State, the Delhi High Court ordered Tihar Jail's prison administration to provide
prisoners with counselling and meditation treatment.4

2.3. Right to a speedy trial

The right to a quick trial is stated in Section 309 of the Criminal Procedure Code. Equity in the
criminal judicial system is guaranteed by the right. However, there are problems with how these
rules are actually enforced. In the case of A.R. Antulay v. R.S. Nayak, the court made some
observations that would guarantee that inmates' human rights would not be violated. It was
claimed that charges at any step, including request, trial, examination, amendment, etc., are
subject to the right to a prompt trial that is outlined in Article 21 of the Constitution.. 5

2.4. Right against Inhuman Treatment of Prisoners

India should adhere to the Human Rights Declaration because it signed the Universal Declaration
of Human Rights in 1948. This text outlines the fundamental rules for administering justice,
including: No person should be subjected to torture, cruel, inhuman or degrading treatment, or
punishment.

Everyone has the right to life and personal freedom. Arrests and detentions should not be made
arbitrarily. In the instance of a criminal offence, everyone has the right to be presumed innocent
unless proven guilty.

In Raghubir Singh v. the State of Bihar, the court punished an officer who had been held
accountable for the death of a suspect while in the police lock-up in order to show its concern
about police abuse. This demonstrates that protecting human rights would result in judicial action
since they are a crucial component of human dignity.

IV. UNDER TRIAL PRISONERS

The Indian criminal justice system is not complete without prisons and other correctional
institutions. The status of the Indian jail system, however, is little mentioned. The group of
people housed in these institutions who are awaiting trial is particularly neglected. The subject of
undertrial inmates in India initially came to light in 1979 when KF Rustomji, a member of the

4
Sanjay V. State of Delhi, CRL.A.600 of 2000.
5
A.R. Antulay v. R.S. Nayak, AIR 1988 SC 1531.

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National Police Commission, published an article in the Indian Express detailing the conditions
of undertrials in Bihar jails..6

In this article, the undertrial detention situation in India is highlighted. The author contends that
recent legal changes and inadequate court decision implementation are the main causes of the
huge numbers of people awaiting trial and the ensuing jail overcrowding..

4.1. DEFINITIONS

An undertrial prisoner is an unconvicted person who has been held in custody during the period
of investigation, inquiry, or trial for the offence he or she is accused of having committed, under
any law, according to Sections 428 and 436A of the CrPC and the 78th Report of the Law
Commission of India. Therefore, it covers situations when neither a charge sheet nor a trial have
been started.

Persons charged with non-bailable offences who have been refused release on bail, or those
accused with non-bailable offences who have been granted bail by the court, or those charged
with bailable offences for whom bail is a matter of right, are included in undertrial detainees.

4.2. STATISTICAL ANALYSIS

There are 1350 jails in India overall, according to Prison Statistics India 2019, a study published
by the National Crime Record Bureau (NCRB). Compared to 2018, the number of inmates
climbed by 2.69% while jail capacity increased by 1.90%. As a result, between 2018 and 2019,
the occupancy rate climbed from 117.6% to 118.5%. Over the years, this rate has been very
steady.

6
Gupta Vidushi, “The state of undertrial incarceration in India”, THE CRIMINAL LAW BLOG National Law
University, Jodhpur, 2020, Available at - https://criminallawstudiesnluj.wordpress.com/2020/10/25/the-state-of-
undertrial-incarceration
inindia/#:~:text=Undertrial%20prisoners%20formed%2070%25%20of,only%2091%20were%20civil%20inmates.
(Accessed on - 8 April 2023)

8
A prison's high occupancy rate is a sign that it is overcrowded. This is a result of the enormous
number of convicts awaiting trial. Based on the number of people awaiting trial, India comes in
at number 15 out of 217 nations. In 2019, convicts awaiting trial made about 70% of the whole
jail population. This percentage has been continuously high over the years, averaging 66.97%.
detainees awaiting trial climbed by 2.15% between 2018 and 2019, however only 91 of them
were civil detainees.7

According to the Prison Report, many people who are awaiting trial stay in jail for a long time.
74.08% of undertrials were imprisoned for up to a year, 13.35% for between one and two years,
6.79% for between two and three years, 4.25% for between three and five years, and 1.52% for
five years or more.

4.3. UNDER TRIALS OR CONVICTED

“Justice delayed is Justice denied”

More than 0.2 million untried inmates in India's criminal justice system were kept behind bars
for years on end, often serving sentences that were more than the maximum allowed for the
crime they had committed. The poor continued to suffer in jails due to a lack of cooperation
between the Centre, Judiciary, and State Governments as well as the fact that they lacked assets
to utilise as bail bonds or guarantors. There have been instances where the bail was too high.

the Indian Constitution, the Standard, and the Universal Declaration of Human Rights. The
Minimum Rules for Treatment of Prisoners make explicit the expectations for handling
defendants in custody. However, the reality within prisons plays a very different melody. 8

Given Below are some challenges that every under-trial prisoner goes through in Indian jails.

Criminalizing effect of Prison

First-time, circumstantial, and youthful offenders commonly become seasoned criminals because
to the presence of hardened criminals and the lack of scientific categorization techniques to

7
Ibid.
8
Ritwik, Sneha & Garg Rishabh, “The Problems of Undertrials”, Legal Service India, ISBN 978-81-928510-1-3,
Available at - http://www.legalservicesindia.com/article/1280/The-Problems-of-Undertrials.html (Accessed on 8
April 2023)

9
distinguish them from others. It is a common saying that "prisons are Universities of Crime,"
where people enter as undergrads and leave with PhDs in criminal behaviour. 9

Health Problems
Most jails struggle with overcrowding and a lack of capacity to house convicts in a secure and
healthy environment. Most inmates come from socioeconomically underprivileged areas of
society where illness, starvation, and a lack of medical care are common. Infectious and
communicable illnesses are easily disseminated when such persons are crowded together under
unsanitary surroundings. According to a sample research undertaken by India's National Human
Rights Commission in the early part of 1998, tuberculosis was to blame for 76% of fatalities in
Indian jails.

Drug Abuse
People arrested for violations of anti-drug legislation make up a significant portion of the jail
population, followed by those convicted of murder, attempted murder, and other major crimes
against persons. Due to their isolation from the outside world while incarcerated, inmates
become more desperate to get illegal narcotics to feed their drug addiction. Since "prison is an
environment where there is a captive, bored, mostly depressed population eager for some release
from the grim everyday reality," this also raises the risk of new inmates being introduced to drug
misuse.

V. PROBLEMS OF PRISON IN INDIA

Only from the outset has jail overcrowding been a source of grave worry. Reducing the number
of individuals undergoing trials is the only way to relieve jail congestion. Without the courts' and
the police's mutual collaboration, this is impossible. Due to their complex processes, fast trials
have the disadvantage of placing a strain on the courts. The victims are frequently burdened by
the police's unwillingness to do their jobs and the defence attorneys' improper attitude, which
leads to their conviction on minor counts. Fast speed courts won't have much of an impact unless
the jail administration and other authorities exert all of their effort.

9
Ibid.

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No matter how appetising a poison may appear, a person will never ingest it if he is aware of its
negative repercussions. The penitentiary likewise has the same situation. No one wants to enter
in to see how luxurious they are. It's challenging to be distant from friends and family. It's not
necessary to create lavish conditions in order to create decent conditions. It indicates that efforts
are being made to improve living circumstances for people. 10

In jails all across the world, extortion by prison officials and its less violent cousin, guard
corruption, are widespread practises. These issues are predicted given the significant control that
guards have over convicts, but they are made worse by the typical low pay for guards. Inmates
pay bribes to guards to supplement their pay in exchange for contraband or special treatment.
While their less fortunate brothers suffered in misery, powerful convicts in several prisons in
Colombia, India, and Mexico had access to cellphones, a lavish food, and nice accommodations.
A PhD dissertation from Punjab University on "The Functioning of Punjab Prisons: An appraisal
in the context of correctional objectives" that was never published alleges several examples of
corruption in jail. Another article suggested that food services are the most common sources of
corruption in the Punjab jails. Ninety five percent of prisoners felt dissatisfied and disgusted with
the food served.11

Although the criminal histories of the convicts and their behaviour while incarcerated should be
the only elements that impact their terms of incarceration, additional factors are significant in
many nations. According to this research by Human Rights Watch, there is a "rigid" class
structure in place in jails in nations like Pakistan and India. It claims that under this system, a
minority of inmates from the upper and middle classes receive preferential benefits regardless of
the crimes they have done or how they behave while there.. 12

10
Sharma Utkarsh, “Major Problems of Prison Administration in India”, INTERNATIONAL JOURNAL OF
LEGAL SCIENCE AND INNOVATION[ISSN 2581-9453],Volume 2 | Issue 1, 2020, Available at -
https://www.ijlsi.com/wp-content/uploads/2020/08/Major-Problems-of-Prison-Administration-in-India.pdf
(Accessed on - 9 April 2023)
11
Available at - https://home.rajasthan.gov.in/content/dam/pdf/StaffCorner/Training-Material/UsefulPresentations-
And-Videos/Overview%20of%20prisons%20in%20India.pdf(Accessed on - 9 April 2023)
12
Ibid.

11
 VI. EDUCATIONAL REFORMS

Studies from all across the world have shown that studying while incarcerated helps whole
civilizations over the long run. In fact, a study conducted in the USA found that those who
engaged in educational courses of any kind while incarcerated had a 43% lower risk of
reoffending.13

This is primarily because, among other things, research has demonstrated that education in jail
has important personal advantages, including increased possibilities for employment after
release, increased political involvement and volunteerism, and better health outcomes. On the
other hand, ex-offenders with poor levels of education frequently struggle to find employment or
social networks, which raises their risk of committing crimes and returning to incarceration.
Since prison education is a topic that the country's judicial system ignores, it is unfortunate that it
is hard to find related research in India.

There isn't much concrete data to back up the idea that jail education in India would provide
results that are comparable, but one may infer that it would. However, it is important to
emphasise that the majority of convicts in India are either illiterate or very poorly educated.

According to the 2003 Model Prison Manual, "Education is vital for the overall development of
prisoners...it leads to their rehabilitation and self-sufficiency...," it is imperative to provide
educational facilities for inmates.It is a tool that may be used to mould an inmate's knowledge,
character, and behaviour. It aids a prisoner's eventual reintegration into society and social
environment adjustment. Similar to this, the National Human Rights Commission published wide
guidelines in their annual report for 2004–2005 noting that inmates must have access to books
and other educational resources to help them develop their abilities and overall personalities. It
was specified that every jail should maintain a library proportionate to the number of inmates
confined, with special consideration being given to the construction of appropriate recreational
and instructional resources for women inmates as well as for those who may be young or
illiterate. The research also emphasised the importance of developing educational programming
that take into account the convicts' educational and cultural backgrounds. Finally, it noted that

13
Irving Doug, “The Case for Correctional Education in U.S. Prisons”, Rand Review, 2016, Available at -
https://www.rand.org/blog/rand-review/2016/01/course-correction-the-case-for-correctional-education.html
(Accessed on - 9 April 2023)

12
"The Superintendent of the Jail should be guided by law in assessing the content of reading
materials; he should not exercise his discretion arbitrarily." 14

Less than 25% of India's 466,084 convicts acquired education, while just approximately 11%
received vocational training, according to 2018 Prison Statistics India. Additionally, the
vocational training provided to prisoners is rarely useful to them after release because there aren't
many employment opportunities or lucrative careers in such sectors. Studies have demonstrated
that this has very seldom happened, despite the 2003 Model Prison Manual's recommendation
that vocational courses be regularly revised. A lack of enthusiasm or motivation among prisoners
is further exacerbated by the fact that many teachers are inexperienced and underpaid, that tools
and equipment are frequently unavailable, that raw materials are few, and that the things
produced as a result are of poor quality. 15

Additionally, convicts are sometimes placed in specific classes based on seat availability without
consideration for their aptitude or interests. Prisoners are frequently paid less than the minimum
wage for their job, which is intended to give employment some dignity and worth and to provide
some financial security after release. Therefore, a closer look reveals that vocational training
courses in Indian jails are more punishing than reformative. The absence of individual autonomy
to choose a programme, the inability to choose whether to work at all, and the poor remuneration
imply that the current programmes are tokenistic and exist mainly to satisfy particular
government requirements rather than for the benefit of inmates. 16

VII. CONCLUSION

By putting into practise the updated legislative provisions, court rulings addressing the rights of
undertrials, arrests and the granting of bail, and the recommendations of different committees on
prison reforms, the emphasis should be on lowering the population of those who are still

14
Bureau of Police Research and Development,Ministry of Home Affairs&Government of India, “MODEL
PRISON MANUAL FOR THE SUPERINTENDENCE AND MANAGEMENT OF PRISONS IN INDIA”, 2003,
Available at - https://bprd.nic.in/WriteReadData/userfiles/file/5230647148-Model%20Prison%20Manual.pdf
(Accessed on – 9 April 2023)
15
Ibid.
16
Team SRPF, “Prisoners’ Educational Reforms in India: An Institutionalised Insufficiency”, Social & Political
Research Foundation, 2020, Available at - https://sprf.in/prisoners-educational-reforms-in-india-aninstitutionalised-
insufficiency/(Accessed on 9 April 2023)

13
awaiting trial. Additionally, to eliminate the punitive nature of incarceration, undertrials should
be placed in open jails where they may walk around freely and make a living. In terms of food,
clothes, water, medical services, sanitization, leisure, and connection with family and solicitors,
they should be given greater facilities than prisoners.

Since its foundation, NHRC has concentrated its efforts on advancing and defending the human
rights of inmates. If a mentally sick person was discovered in a prison when the Commission was
inspecting it, it would provide them or their family members compensation. The Commission
had given instructions/guidelines stating that no mentally ill person should be housed in a prison.
Such compensation can be recovered by the State Government from the negligent correctional
staff. The Commission had also sent a letter to the Chief Justices of the High Courts requesting
that cases be tried quickly, detainees who were awaiting trial be released, and that the District
and Sessions Judges receive the proper instructions so that they can visit jails often as required
by the State Prison Manuals. All prison administrations had also received directives from the
Commission demanding mandatory health screenings for all inmates as well as frequent
reporting to the Commission. The Commission has also addressed the issue of inmates who are
serving life sentences being released too soon.

The Indian prison system has long been portrayed in the media, both print and digital, with a
strongly political viewpoint that frequently depicts jails as a brutal and xenophobic shelter for
criminals. And this opinion persists despite a number of commendable actions made by jail
officials, including vocational training, literacy campaigns, computer classes, sports training, and
routine medical examinations of inmates. But the reality remains that only prison complexes like
Tihar and Yerwada continue to use such practises. Prison reforms in India will remain an artifice
until such measures don't impact the jails in the undesirable hinterlands of India.

Structural adjustments are required to solve the main problems in Indian prisons, which have
been labelled as a university for breeding criminals. Otherwise, jails will continue to be both
heaven and hell for criminals with connections to the political system and socioeconomically
disadvantaged defendants.

14
 VIII. REFERENCES

 Sudipto Roy, Jail Reforms in India: A Review, 11 Kriminologija i Socijalna Integracija

41,41 (2003).
 Brij Mohan, b. Prison Problems in India, 16 INT. J. OFFENDER THERAPY & COMP.
CRIMINOLOGY 32 (1972).
 PACHAURI, S.K. “HISTORY OF PRISON ADMINISTRATION IN INDIA IN 19TH
CENTURY: HUMAN RIGHTS IN RETROSPECT.” Proceedings of the Indian History
Congress, vol. 55, 1994, pp. 492–498., Available at - www.jstor.org/stable/44143401
(Accessed on 14 May 2021)
 Team SRPF, “Prisoners’ Educational Reforms in India: An Institutionalised
Insufficiency”, Social & Political Research Foundation, 2020, Available at -
https://sprf.in/prisoners-educational-reforms-in-india-an-institutionalisedinsufficiency/
(Accessed on 11 May 2021)
 Sharma Utkarsh, “Major Problems of Prison Administration in India”,
INTERNATIONAL JOURNAL OF LEGAL SCIENCE AND INNOVATION [ISSN
2581- 9453], Volume 2 | Issue 1, 2020, Available at -
https://www.ijlsi.com/wpcontent/uploads/2020/08/Major-Problems-of-Prison-
Administration-in-India.pdf (Accessed on - 9 May 2021)
 Mitali Agarwal, Beyond the Prison Bars: Contemplating Community Sentencing in India,
12 NUJS L. REV. 119 (2019)

15