Protection of persons in prostitution-related cases: Call to implement Supreme Court directives

Date: 24/08/2026

To,
A. Revanth Reddy
Chief Minister of Telangana.

Sub: Implementation of Supreme Court directions regarding protection persons in prostitution-related cases and prevention of police misconduct rescue operations.

(Through Mr. V. Sheshadri, IAS, Principal Secretary to CM)

Sir,
Human Rights Forum draws your attention to the recent judgment of the Hon’ble Supreme Court in Prajwala v. Union of India, wherein the Court laid down a comprehensive Victim Protection Plan and issued important directions governing the conduct of state authorities dealing with persons found in prostitution-related situations.

Human Rights Forum, welcomes the judgement and the directions it has issued with respect to protection of victims of trafficking for commercial sexual exploitation and their right to rehabilitation. We also welcome the much needed distinction established by the Hon’ble Supreme Court under Article 32 and 142 between sex trafficking and prostitution, including recognising voluntary adult sex work.

The judgment is significant because it places the human rights, dignity, autonomy and constitutional protections of affected persons at the centre of all state action. The Court has recognised that persons involved in prostitution-related situations often belong to highly marginalised and stigmatised sections of society and are vulnerable not only to exploitation but also to abuse and discrimination by state agencies themselves.

The Supreme Court has therefore held that all authorities must be guided by certain fundamental principles, including:

  • ⁠Primacy of human rights and dignity.
  • Non-criminalisation of victims.
  • Respect for informed consent and personal autonomy.
  • ⁠Non-discrimination and non-stigmatisation.
  • Protection of privacy and confidentiality.
  • Right to information regarding legal rights and entitlements. Individualised assessment of circumstances and needs.
  • Protection from further exploitation and harm.

The Court has specifically observed that measures undertaken in the name of rescue, care, protection or rehabilitation must not themselves become sources of coercion, humiliation or rights violations of particular relevance to the Home Department are the observations of the Court regarding police conduct. The judgment records concerns regarding instances of verbal abuse, physical violence, intimidation, humiliation and other forms of misconduct during raids and rescue operations.

The Court notes that such conduct is frequently enabled by prevalling social prejudices and moral attitudes towards persons engaged in prostitution.

To address these concerns, the Court has laid down mandatory safeguards to be observed by all officials participating in rescue operations. These include:

  • No person shall be subjected to verbal or physical abuse.
  • Rescue operations shall not involve unnecessary force, Intimidation or manhandling.
  • No acts constituting criminal offences shall be committed by officials in the course of rescue operations.
  • ⁠All actions must respect the dignity, privacy and human rights of the persons concerned.
  • Persons encountered during rescue operations shall not be treated as criminals merely because of their involvement in prostitution.

The Court has further emphasised that protection cannot be made conditional upon a person’s willingness to cooperate with law-enforcement agencies or participate in criminal proceedings. It has also stressed the importance of maintaining confidentiality and preventing disclosure of identities.

The judgment contains important observations regarding the inhuman treatment often experienced by voluntary adult sex workers and acknowledges the need for effective mechanisms through which complaints regarding police excesses can be addressed. The Court has recognised that moral disapproval cannot justify violations of constitutional rights.

In light of the above, Human Rights Forum requests the Government to:

  1. Issue comprehensive instructions to all Commissioners of Police, Superintendents of Police, Station House Officers and investigating officers regarding implementation of the Supreme Court’s directions.
  2. ⁠Direct all police personnel to strictly comply with the principles of dignity, non- discrimination, privacy, confidentiality and non-criminalisation laid down by the Court.
  3. Ensure that no person is subjected to verbal abuse, physical violence, intimidation, coercion or humiliation during rescue operations.
  4. ⁠Develop and implement mandatory sensitisation programmes for all police personnel dealing with trafficking, prostitution-related offences and rescue operations.
  5. ⁠Incorporate the Supreme Court’s directions into police manuals, standing orders, training curricula and operational protocols.
  6. ⁠Establish accessible complaint and monitoring mechanisms to inquire into allegations of police misconduct and violations of the rights of affected persons.
  7. ⁠Require supervisory officers to periodically review compliance and initiate disciplinary action wherever violations are found.

The Supreme Court’s judgment presents an important opportunity to align policing practices with constitutional values of dignity, equality, liberty and human rights. We therefore request the Home Department to take immediate steps to ensure effective implementation of these directions throughout the State. A copy of the Judgement is enclosed with this Representation.

Yours Sincerely,

Dr. S. Thirupathaiah – HRF Telangana State General Secretary
V. Vasanthalakshmi – HRF TG & AP Coordination Committee Member
S. Jeevan Kumar – HRF TG & AP Coordination Committee Member
Sanjeev – HRF City Unit Secretary

Copy to:
1.⁠ ⁠Principal Secretary, Women and Child Welfare Department, Govt. of Telangana.
2. Director General of Police, Govt. of Telangana.
3. Principal Secretary, Home Dept., Govt. of Telangana.

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