Sunday, 26 October 2025

Criminal Offences and Trials under The Rights of Persons with Disabilities Act, 2016: Role of JMFC and Session Judge

The Rights of Persons with Disabilities Act, 2016 stands as a monumental piece of legislation that not only grants comprehensive rights to persons with disabilities but also creates a robust criminal justice framework to protect them from atrocities and discrimination. While much attention is given to the rights and entitlements under this Act, the penal provisions and trial procedures remain lesser explored territories that demand judicial scrutiny and understanding.

The Criminal Justice Architecture Under RPWD Act 2016

The RPWD Act 2016 represents a paradigm shift from the erstwhile Persons with Disabilities (Equal Opportunities, Protection of Rights and Full Participation) Act, 1995. Chapter XVI of the Act (Sections 89-95) creates a comprehensive penal framework that criminalizes various forms of discrimination, atrocities, and violations against persons with disabilities, transforming what were once civil wrongs into cognizable criminal offences.

Section 92: The Crown Jewel of Criminal Protection

Section 92: Punishment for Offences of Atrocities emerges as the most significant penal provision under the RPWD Act, creating six distinct categories of criminal offences specifically targeting the vulnerabilities of persons with disabilities.

The Six-Fold Criminal Shield

1. Intentional Insult or Intimidation [Section 92(a)]

The provision criminalizes intentional insult or intimidation with intent to humiliate a person with disability in any place within public view. This provision recognizes that dignity is not merely a moral concept but a legal right enforceable through criminal law.

2. Assault or Use of Force [Section 92(b)]

This encompasses assaulting or using force against any person with disability with intent to dishonour them or outrage the modesty of a woman with disability. The provision acknowledges the heightened vulnerability of persons with disabilities to physical violence and sexual offences.

3. Denial of Food or Fluids [Section 92(c)]

The Act criminalizes having actual charge or control over a person with disability and voluntarily or knowingly denying food or fluids. This provision addresses the grave concern of neglect and abandonment, particularly in institutional settings.

4. Sexual Exploitation [Section 92(d)]

Being in a position to dominate the will of a child or woman with disability and using that position to exploit her sexually constitutes a criminal offence. This provision recognizes the power dynamics that make persons with disabilities particularly vulnerable to sexual exploitation.

5. Injury to Limbs or Senses [Section 92(e)]

Voluntarily injuring, damaging or interfering with the use of any limb or sense or any supporting device of a person with disability is criminalized. This provision protects not only the physical integrity but also the assistive devices that enable independence.

6. Unauthorized Medical Termination of Pregnancy [Section 92(f)]

The provision criminalizes performing, conducting or directing any medical procedure on a woman with disability which leads to termination of pregnancy without her express consent, except in severe cases with proper medical opinion and guardian consent.


The Penal Consequences: Deterrence Through Punishment

All offences under Section 92 carry a punishment of imprisonment for a term which shall not be less than six months but which may extend to five years and with fine. The mandatory minimum sentence of six months reflects the legislative intent to create a strong deterrent against atrocities on persons with disabilities.

Classification of Offences: The Procedural Framework

According to Ministry of Home Affairs guidelines, offences under Section 92 are cognizable, non-bailable and triable by a Magistrate of First Class. This classification has significant procedural implications:

             Cognizable Nature: Police can arrest without warrant

             Non-bailable Character: Accused cannot claim bail as a matter of right

             Triability: Creates jurisdictional questions regarding trial court

The Broader Penal Canvas: Other Criminal Provisions

Section 89: Contravention of Provisions

The Act creates a graduated punishment system for violations: - First contravention: Fine up to ₹10,000 - Subsequent contravention: Fine not less than ₹50,000 but may extend to ₹5 lakh

Section 91: Fraudulent Availment of Benefits

Fraudulent availment of benefits meant for persons with benchmark disabilities attracts imprisonment up to two years or fine up to ₹1 lakh or both, addressing the misuse of disability benefits.

Section 93: Failure to Furnish Information

Non-compliance with information requirements attracts fine up to ₹25,000, with continuing violation penalty of ₹1,000 per day.

Section 94: Prior Sanction Requirement

The Act requires previous sanction of appropriate Government before taking cognizance of offences committed by government employees, creating a safeguard against frivolous prosecutions.

The Special Court Architecture: Section 84 Revolution

Constitutional Mandate for Special Courts

Section 84 of the RPWD Act mandates the establishment of Special Courts, stating: “For the purpose of providing speedy trial, the State Government shall, with the concurrence of the Chief Justice of the High Court, by notification, specify for each district, a Court of Session to be a Special Court to try the offences under this Act.”

This provision represents a legislative recognition that ordinary criminal justice machinery may be inadequate to handle the specialized nature of disability-related offences.

The Special Prosecutor Framework

Section 85 complements the Special Court system by requiring appointment of Special Public Prosecutors with at least seven years of practice, ensuring specialized prosecution expertise.

Jurisdictional Complexities: The Trial Procedure Conundrum

The Sentencing Power Paradox

A critical legal issue emerges from the intersection of various provisions:

             Section 92 RPWD Act: Punishment extends to 5 years

             Section 23(2) BNSS: Magistrate First Class can sentence only up to 3 years

             MHA Guidelines: State offences are triable by Magistrate First Class

This creates an apparent contradiction requiring judicial interpretation.

The Resolution: Special Court Framework

The contradiction is resolved through Section 84, which designates Sessions Courts as Special Courts for trying RPWD Act offences. The procedure follows this sequence:

1.          Magistrate takes cognizance on police report

2.          Commitment to Special Court under Section 232 BNSS

3.          Trial by Special Court (Sessions Court) with specialized prosecutor

Direct Cognizance Question: The Legal Answer

Sessions Courts cannot take direct cognizance of RPWD Act offences. Despite Section 84 creating Special Courts, it does not expressly empower Sessions Courts to bypass magistrate cognizance. The commitment procedure remains mandatory under Section 232 BNSS.

Implementation Status: From Law to Reality

State-wise Implementation

Various states have moved to implement the Special Court mandate:

             Delhi: Designated Additional Sessions Judge-02 in each district as Special Court (2019)

             Madhya Pradesh: Issued notifications for Special Courts

             National Directive: Supreme Court in 2017 directed all states/UTs to establish Special Courts

Where Special Courts remain undesignated, regular Sessions Courts exercise jurisdiction after proper commitment.

The Commitment Procedure: Bridging Magistrate and Sessions Court

Section 232 BNSS Framework

When a Magistrate receives a charge sheet for Section 92 offences, the commitment procedure under Section 232 BNSS requires:

1.          Compliance with Sections 230-231 BNSS (preliminary proceedings)

2.          Remand of accused to custody (subject to bail)

3.          Transmission of record and evidence to Sessions Court

4.          Notification to Public Prosecutor

5.          Completion within 90 days (extendable to 180 days)

Limitations of Magistrate’s Role

During commitment proceedings, the Magistrate’s role is administrative and limited. The Magistrate cannot probe into merits or discharge the accused if facts disclose a Sessions triable offence.

Contemporary Relevance and Future Directions

Integration with New Criminal Laws

With the implementation of Bharatiya Nagarik Suraksha Sanhita (BNSS) 2023, the RPWD Act’s penal provisions must be read harmoniously with the new procedural framework while maintaining their specialized character.

Challenges in Implementation

1.          Lack of awareness among investigating agencies about RPWD Act provisions

2.          Inadequate training of police and judicial officers

3.          Delayed establishment of Special Courts in many states

4.          Coordination issues between disability welfare departments and criminal justice system

Conclusion: Towards Inclusive Criminal Justice

The RPWD Act 2016’s criminal justice framework represents a legislative masterpiece that transforms disability rights from mere welfare concerns to enforceable criminal law protections. The Act’s penal provisions, anchored by Section 92’s comprehensive offence categories and supported by the Special Court architecture under Section 84, create a robust shield against atrocities on persons with disabilities.

However, the true test of this legislative framework lies not in its textual elegance but in its implementation reality. The establishment of Special Courts, training of specialized prosecutors, and creation of disability-sensitive investigation procedures remain critical for translating the Act’s vision into ground reality.


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