Undertrial Prisoner Entitled To Food Suited To His Medical Condition: Chennai Court

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Published 31 October 2026

Case: Anbil Mahesh Poyyamozhi v. The Superintendent, Central Prison, Puzhal, Chennai
Bench: S. Alli
Decided: 10 June 2024
Statutes: Tamil Nadu Prisons Rules, 1983 — s.33
Source: LiveLaw

Bottom Line Up Front (BLUF)

In Anbil Mahesh Poyyamozhi v. The Superintendent, Central Prison, Puzhal, Chennai, the Principal Sessions Court, Chennai, on 2024-06-10, held that an undertrial prisoner is entitled to food suited to his medical condition, allowing home-cooked food. The court referred to Section 33 of the Tamil Nadu Prisons Rules, 1983.

Ratio Decidendi · Legal Principle Established

An undertrial prisoner has a right to receive food that is suitable for their medical condition, and this right can extend to permitting home-cooked food if prison facilities cannot adequately cater to such needs, as per Section 33 of the Tamil Nadu Prisons Rules, 1983.

Practice & Procedural Impact for Advocates

Advocates representing undertrial prisoners with medical conditions should specifically cite Section 33 of the Tamil Nadu Prisons Rules, 1983 (or equivalent state prison rules) when seeking permission for special dietary needs or home-cooked food. Litigants should provide clear medical documentation supporting the need for a specific diet to strengthen their application.

Key Legal Takeaways

1Undertrial prisoners have a right to food suitable for their medical condition.
2Courts can permit home-cooked food if prison facilities cannot meet medical dietary needs.
3Section 33 of the Tamil Nadu Prisons Rules, 1983, supports such entitlements.

The Legal Issue Anbil Mahesh Poyyamozhi, an undertrial prisoner, filed a petition seeking permission to receive home-cooked food while in judicial custody at Central Prison, Puzhal, Chennai. The petitioner contended that due to his medical condition, he required a specific diet that could not be adequately provided by the prison authorities. The application was made before the Principal Sessions Court, Chennai.

Court's Reasoning Justice S. Alli of the Principal Sessions Court, Chennai, considered the petitioner's medical condition and the provisions of the Tamil Nadu Prisons Rules, 1983. The court specifically referred to Section 33 of the Tamil Nadu Prisons Rules, 1983, which states that 'Every prisoner shall be supplied with food according to the scale of diet prescribed in the rules.' While the rule generally refers to prison-supplied food, the court interpreted it to encompass the right of a prisoner to receive food suited to their medical condition. The court acknowledged that in cases where the prison cannot provide such specialized dietary requirements, allowing home-cooked food becomes a necessary measure to protect the prisoner's health and fundamental rights.

What Follows The Principal Sessions Court, Chennai, allowed the petition filed by Anbil Mahesh Poyyamozhi. The court directed the Superintendent of Central Prison, Puzhal, Chennai, to permit the petitioner to receive home-cooked food, subject to necessary security checks and adherence to prison regulations. This order ensures that the undertrial prisoner's medical dietary needs are met during his judicial custody.