Supreme Court Issues Nationwide Standards for Beggars’ Homes, Holds State Accountable for Dignified Care

A bench of Justice J.B. Pardiwala and Justice R. Mahadevan heard an appeal by M.S. Patter challenging an order of the Delhi High Court which, in July 2003, had disposed of an application seeking enforcement of its earlier directions concerning multiple deaths and an outbreak of cholera and gastroenteritis at the Lampur (Narela) Beggars’ Home. The appeal raised questions of compliance with the High Court’s directions, accountability for the deaths of inmates, and the broader constitutional standards applicable to State‑run institutions for indigent persons.

The Supreme Court held that the authorities had, by and large, implemented the High Court’s directions and this appeal was accordingly disposed of, but it issued comprehensive nationwide directions to ensure that Beggars’ Homes and analogous institutions complied with constitutional guarantees of life and dignity. The Court emphasised that such institutions must be “restorative, not retributive,” and must function as a constitutional trust rather than a discretionary charity. The Court, in its reasoning, observed: The Court directed States and Union Territories to implement minimum standards of healthcare, sanitation, nutrition, infrastructure, vocational training, legal aid and oversight, and required the Union to issue model guidelines within three months and for all directions to be implemented within six months.

Background The petition originated from media reports in May 2000 alleging an outbreak of cholera and gastroenteritis at the Lampur Beggars’ Home and reporting multiple deaths. The appellant filed a public interest writ petition in the Delhi High Court seeking fixation of responsibility, compensation to dependents, and punishment of officials. Investigations by the SDM and an inquiry officer recorded contamination of drinking water, presence of E. coli and failures in chlorination and maintenance; the High Court reproduced findings that "the probable cause of death is stated to be the passage of human excreta into the drinking water and subsequent passage of vibrio cholera bacteria." The High Court directed remedial measures, departmental inquiries and completion of improvements within six months by its order dated 15.10.2001. The appellant later filed an application alleging non‑compliance; the High Court disposed of that application by granting liberty to approach the appropriate forum without a reasoned order, prompting the present appeal.

The State submitted that disciplinary proceedings against responsible officers had been completed and penalties imposed, and that numerous infrastructural and welfare measures had been taken. The Supreme Court reviewed an extensive administrative record and a series of supervisory orders, site inspections, compliance affidavits and surprise visits conducted over two decades. The Court recorded persistent early deficiencies in hygiene, staffing, medical care and kitchen facilities, noted progressive remedial work ordered by it (including mandatory medical screening, dietician oversight, renovation, CCTV and security, staff increases and vocational training), and accepted recent inspection reports finding the subject homes “well‑organised, neat and clean” with inmates raising no complaints about food quality or quantity. The Court found that the High Court’s substantive directions in 2001 stood complied with in letter and spirit, but it held that systemic reforms must be institutionalised across all Beggars’ Homes nationally to prevent recurrence and to secure Article 21 rights.

The final result was that the appeal was disposed of with detailed directions applying to all State/UT Beggars’ Homes: mandatory medical screening and monthly health checks; potable water, functional toilets and pest control; occupancy limits and biennial third‑party infrastructure audits; appointment of dieticians and standardised dietary protocols; expansion of vocational training and rehabilitation; legal aid visits; child and gender sensitive measures; a monitoring committee in each State/UT; compensation and departmental/criminal proceedings where deaths resulted from negligence; a centralised digital inmate database; model guidelines from the Union within three months; and implementation within six months. Liberty was reserved to seek further directions.

Case Details: Case No.: Civil Appeal No. 12216 of 2025 (Arising out of SLP (C) No. 878 of 2004) (2025 INSC 1115) Case Title: M.S. Patter v. State of NCT of Delhi and Others Appearances: For the Petitioner(s): (not specified in the reported extract) For the Respondent(s): Ms. Madhavi Divan, Additional Solicitor General of India; Mr. Sanjay Kapur, Advocate‑on‑Record; Mr. Ranjit Kumar, Senior Counsel (appointed as Amicus Curiae)