Incarcerated Minds: Examining India’s Prison Mental Health Crisis through a Psycho-Legal Lens

Abstract

The mental health of prisoners has emerged as a critical yet overlooked concern within India’s criminal justice system. In 2025, the suicide of a mentally distressed under-trial prisoner in a Maharashtra jail brought renewed attention to the inadequacies of mental healthcare in custodial settings.

This article examines the issue of prison mental health as a recent legal development, analyzing its implications through a psycho-legal lens. It explores the psychological impact of incarceration, particularly on under-trial prisoners, and evaluates the State’s legal obligations under Article 21 of the Constitution and the Mental Healthcare Act, 2017.

Introduction

Prisons are an essential part of the criminal justice system, but most of the time they remain distant from public scrutiny. Incarceration lawfully restricts personal liberty, which does not mean it should strip individuals of basic rights, dignity, or access to healthcare.

In 2025, a deeply troubling incident occurred in a Maharashtra jail, where an under-trial prisoner died by suicide despite reportedly receiving psychiatric care. This incident is not an isolated tragedy but a reflection of a wider and persistent crisis within Indian prisons. It exposes serious gaps in mental health assessment, treatment, and suicide-prevention mechanisms in custodial settings. More importantly, it raises pressing legal questions regarding the State’s duty of care, the protection of life and dignity under Article 21 of the Constitution, and the effective implementation of the Mental Healthcare Act, 2017.

This incident constitutes a significant legal development within the criminal justice system, as custodial deaths and suicides directly engage constitutional safeguards and state accountability. Through a psycho-legal lens, this article examines how mental health failures in prisons undermine fundamental rights, weaken the reformative purpose of punishment, and demand urgent legal and institutional reform.

Mental Health and Incarceration: The Indian Context

Mental health issues among prisoners aren’t a new phenomenon, but they are often ignored within the Indian criminal justice system. Imprisonment involves more than physical confinement; it brings emotional stress, uncertainty, fear, and social isolation. For many inmates, especially under-trial prisoners, these conditions significantly worsen existing mental health problems or give rise to new ones such as depression, anxiety, and suicidal tendencies.

Indian prisons are severely overcrowded, understaffed, and under-resourced. Once incarcerated, prisoners face limited access to mental health professionals, poor living conditions, lack of privacy, and prolonged separation from family, all of which further aggravate their mental state. Under-trial prisoners are particularly vulnerable because they often remain in custody for long periods without certainty about their future or the outcome of their cases.

From a psychological perspective, prolonged detention without conviction can lead to feelings of helplessness, hopelessness, and loss of identity. Studies and reports by prison reform committees have consistently highlighted that Indian prisons lack adequate numbers of trained psychiatrists, psychologists, and social workers to address these issues effectively.

The failure to integrate mental healthcare into everyday prison management reflects a deeper systemic neglect, where punishment takes precedence over rehabilitation and human dignity. This gap between psychological need and institutional response forms the foundation of the larger prison mental health crisis in India.

The Recent Legal Development: Custodial Suicide in Maharashtra (2025)

In 2025, a disturbing incident was reported from a jail in Maharashtra where an under-trial prisoner died by suicide while in judicial custody. The prisoner was reportedly undergoing psychiatric treatment and had shown signs of prolonged mental distress. Despite this, the custodial system failed to prevent the loss of life. This incident has brought renewed attention to the fragile state of mental healthcare in Indian prisons and has raised serious legal and constitutional concerns.

The fact that the deceased was an under-trial prisoner is particularly significant. Under-trial inmates are legally presumed innocent and are detained only to ensure the proper conduct of investigation and trial. Their continued incarceration is not meant to be punitive. Any custodial death or suicide of an under-trial therefore raises immediate questions about the fairness, humanity, and legality of the criminal justice process. Courts in India have consistently held that the State bears a heightened duty of care towards persons in custody, especially those who are mentally vulnerable.[1]

The Supreme Court has recognized that prisoners do not lose their fundamental rights upon incarceration, except to the extent lawfully restricted.[2] When a mentally distressed prisoner takes their own life inside a prison, it suggests a breakdown in the State’s obligation to protect life and dignity under Article 21 of the Constitution.

This incident qualifies as a recent legal development because it exposes the gap between existing legal safeguards and their actual implementation. Despite the enactment of the Mental Healthcare Act, 2017, which guarantees access to mental health services and imposes duties on public authorities, prisons continue to lack effective mechanisms for early identification of suicide risk, continuous psychiatric monitoring, and crisis intervention.[3] The Maharashtra incident is therefore not merely an unfortunate event but a reflection of systemic failure, demanding legal scrutiny, accountability, and reform within the criminal justice system.

Legal Framework Governing Prison Mental Health in India

The legal responsibility to protect the mental health of prisoners in India flows from both constitutional principles and statutory provisions. The Supreme Court has repeatedly interpreted Article 21 of the Constitution—which guarantees the right to life—to include the right to live with human dignity, even for persons who are incarcerated.

Indian constitutional jurisprudence has consistently affirmed that prisoners retain all fundamental rights except those necessarily curtailed by incarceration. In several cases, the courts have emphasized that prison authorities act as custodians and therefore owe a duty of care to inmates. Any failure to provide adequate medical or mental healthcare may amount to a violation of Article 21.[4] This duty becomes even more critical when dealing with prisoners suffering from mental illness or psychological distress.

A significant statutory development in this area is the Mental Healthcare Act, 2017 (MHCA). The Act recognizes mental healthcare as a legal right and places clear obligations on the State to ensure access to mental health services without discrimination. Under the MHCA, persons with mental illness are entitled to timely diagnosis, treatment, and care, including in custodial institutions.[5] The Act also stresses that mental illness should be treated with dignity and that patients must be protected from inhuman or degrading treatment.

In addition to constitutional and statutory safeguards, prison administration in India is governed by prison manuals and jail rules framed by State governments. These rules generally mandate medical examinations, access to healthcare professionals, and special care for prisoners showing signs of mental illness. However, in practice, these provisions often remain poorly implemented due to staff shortages, lack of training, and inadequate infrastructure.

The legal framework governing prison mental health is therefore well-established on paper. Yet, incidents such as custodial suicides reveal a troubling gap between law and reality. The failure to translate these legal protections into effective prison practices exposes the State to constitutional liability and highlights the urgent need for reform-oriented implementation rather than mere legislative recognition.

Psycho-Legal Analysis: Where the System Fails

Despite the existence of constitutional safeguards and statutory protections, the mental healthcare system within Indian prisons continues to suffer from serious structural failures. The most prominent issue is the gap between legal intent and actual implementation. While laws recognize the mental health needs of prisoners, prison administrations often lack the resources, training, and institutional priority required to address those needs effectively.[6]

One of the major failures is the severe shortage of mental health professionals in prisons. Many jails operate without full-time psychiatrists or psychologists, relying instead on occasional visits by medical officers who may not be trained to identify complex mental health conditions. This results in delayed diagnosis, irregular treatment, and poor monitoring of prisoners who are at risk of self-harm or suicide. From a psychological perspective, untreated mental illness in a closed environment can rapidly deteriorate, especially when combined with stressors such as isolation and uncertainty.

Another critical concern is the lack of continuous mental health assessment. Prisoners are typically screened only at the time of admission, if at all. Thereafter, follow-up assessments are rare unless a visible crisis occurs. This reactive approach ignores early warning signs such as withdrawal, behavioral changes, or verbal expressions of distress. Legally, this reflects a failure of the State’s duty of care, as custodial authorities are expected to take preventive measures, not merely respond after harm has occurred.[7]

Prison staff often lack training to understand mental health conditions, leading to misinterpretation of symptoms as indiscipline or non-cooperation. Instead of receiving care, mentally distressed prisoners may face punishment, isolation, or neglect.

From a psycho-legal standpoint, these failures collectively point to a systemic neglect of prisoner mental health. When the legal framework promises dignity and care but the institutional reality delivers indifference, the result is not only psychological harm but also constitutional violation. Custodial suicides are therefore not individual acts alone; they are symptoms of a deeper failure of the criminal justice system to protect those it holds in its custody.

Impact on the Criminal Justice System

The neglect of mental health within prisons has serious consequences for the criminal justice system. Custodial suicides, particularly involving under-trial prisoners, undermine the principles of fairness, dignity, and accountability that the system is expected to uphold. When a person dies by suicide while under State control, it raises fundamental questions about whether constitutional and legal duties have been fulfilled.

Under-trial prisoners are presumed innocent and are often detained for prolonged periods due to systemic delays. Inadequate mental healthcare during such detention intensifies psychological distress and risks turning preventive custody into a form of punishment, a practice that courts have consistently warned against.[8] This weakens the legitimacy of detention and erodes trust in the criminal process.

Custodial suicides also expose the State to constitutional liability. Indian courts have recognized that deaths in custody may warrant public law remedies where failure of duty is evident.[9] Repeated incidents highlight systemic shortcomings rather than isolated lapses, revealing poor coordination between prison authorities, healthcare services, and oversight mechanisms.

Ultimately, the inability to protect the mental well-being of prisoners damages the credibility of the criminal justice system. A system that fails to safeguard the lives and dignity of those in its custody risks being viewed as punitive rather than just, and procedural rather than humane.

The Need for Reform and the Way Forward

Addressing the prison mental health crisis requires moving beyond legal recognition towards meaningful implementation. Regular and mandatory mental health screening of prisoners, particularly under-trials, should be institutionalized at the time of admission and throughout detention. Early identification of psychological distress can significantly reduce the risk of self-harm.

There is also an urgent need to strengthen mental health infrastructure within prisons by appointing trained psychiatrists, psychologists, and counselors on a regular basis. Prison staff must receive basic training to recognize signs of mental illness and respond with care rather than punishment. Coordination between prison departments and public health authorities is essential to ensure continuity of treatment.

Finally, accountability mechanisms must be reinforced. Independent inspections, judicial oversight, and prompt inquiries into custodial suicides can ensure that legal obligations are not reduced to mere formalities. Prison reforms must align with the reformative goals of punishment and uphold the dignity and rights guaranteed under the Constitution.

Conclusion

The 2025 custodial suicide of a mentally distressed under-trial prisoner highlights a disturbing reality within India’s prison system. Despite constitutional guarantees and statutory protections, mental healthcare in custodial settings remains inadequate and inconsistently implemented. This gap between law and practice exposes prisoners to severe psychological harm and places the State in violation of its duty to protect life and dignity under Article 21.

Viewing prison mental health through a psycho-legal lens reveals that custodial suicides are not isolated incidents but indicators of systemic failure. Meaningful reform requires a shift from reactive responses to preventive care, supported by trained personnel, institutional accountability, and humane prison administration. Protecting the mental well-being of prisoners is not an act of charity but a constitutional and legal obligation central to the legitimacy of the criminal justice system.

References

[1] D.K. Basu v. State of West Bengal, (1997) 1 SCC 416. 
[2] Sunil Batra v. Delhi Administration, (1978) 4 SCC 494. 
[3] Mental Healthcare Act, 2017, §§ 18, 19 & 21. 
[4] Charles Sobhraj v. Superintendent, Central Jail, (1978) 4 SCC 104. 
[5] Mental Healthcare Act, 2017, §§ 18–21. 
[6] National Human Rights Commission, Reports on Custodial Deaths in India (various years). 
[7] Nilabati Behera v. State of Orissa, (1993) 2 SCC 746. 
[8] Hussainara Khatoon v. State of Bihar, (1980) 1 SCC 81. 
[9] Nilabati Behera v. State of Orissa, (1993) 2 SCC 746.