Court has said that failure to comply with these guidelines not only renders an officer liable for punishment through departmental action but also amounts to contempt of court. VII. Treatment of Women and Legal Aid Sheela Barse V State of Maharashtra 1983 SCC 96 A. Background Sheela Barse - a journalist and activist for prisoners’ rights - wrote to the Supreme Court saying that of the 15 women prisoners interviewed by her in Bombay Central Jail, five admitted that they had been assaulted in police lock-up. Given the seriousness of the allegations, the Court admitted a writ petition on the basis of the letter and asked the College of Social Work, Bombay to visit the Central Jail to find out whether the allegations were true. The College submitted a detailed report which, in addition to admitting that excesses against women were taking place, pointed out that arrangement for providing legal assistance to prisoners was inadequate. B. Observations by the Supreme Court Failure to provide legal assistance to poor and impoverished persons violates constitutional guarantees. Article 39-A [Directive Principle of State Policy] casts a duty on the State to secure the operation of a legal system that promotes justice on the basis of equal opportunity. The right to legal aid is also a fundamental right under articles 14 [Equality before Law] and 21 [Right to Life and Personal Liberty]. The Court expressed serious concern about the plight of prisoners, unable to afford legal counsel to defend themselves. They said that not having access to a lawyer was responsible for individual rights against harassment and torture not being enforced. Stressing the urgent need to provide legal aid not only to women prisoners but to all prisoners whether they were undertrials or were serving sentences, the Court said that an essential requirement of justice is that every accused person should be defended by a lawyer. Denial of adequate legal representation is likely to result in injustice, and every act of injustice corrodes the foundations of democracy and rule of law. Expressing serious concern about the safety and security of women in police lock-up, the Supreme Court directed that a woman judge should Manual on Human Rights for Police Officers 77