Beneath the solemn domes and echoing corridors of Uttar Pradesh's district courts and tribunals, where the fundamental rights of citizens are passionately defended, lies a silent, shameful contradiction. While legal minds debate the finer points of Article 21 of the Constitution—the Right to Life and Personal Liberty—a stark violation of those very right festers within the court premises, i.e. the deplorable state of public toilets.
For the women who serve and seek justice here—lawyers, litigants, staff, and visitors—these facilities are not merely unpleasant; they are a direct threat to health and dignity. We try to reflect a mirror or expose a squalid reality that transforms a basic human necessity into a gendered health hazard, making a mockery of the constitutional promises of equality and dignity.
While the High Courts in every state and even in Uttar Pradesh may maintain standards, the district and subordinate courts—the true 'people's courts' where the majority seek redress—present a grim picture. Here, the absence of soap, sanitary pads, and even basic cleanliness is not an exception but a norm, with devastating consequences.
The Constitutional and Legal Framework: Unfulfilled Promises
The right to sanitation and hygiene is firmly enshrined in India's legal conscience, deriving from a powerful trinity of constitutional provisions: Article 21, guaranteeing the right to life and personal liberty, has been expansively interpreted by the Supreme Court to include the right to live with human dignity and access to clean sanitation, as affirmed in Vincent Panikurlangara v. Union of India; Article 14, ensuring equality before the law, is violated when inadequate infrastructure creates de facto barriers, a principle reaffirmed in National Legal Services Authority v. Union of India regarding transgender persons; and Article 15's prohibition of discrimination on grounds of sex is directly engaged, as the state's failure to provide gender-adequate sanitation, especially for women, constitutes indirect discrimination. Judicial precedents like Rajeeb Kalita v. Union of India have unequivocally declared toilets a basic necessity and a facet of Article 21, while directives from the Delhi High Court in Smita Kumari Rajgarhia v. State and the Bombay High Court in New Bombay Advocates Welfare Association v. State of Maharashtra have reinforced that providing clean, functional, and secure washrooms is a constitutional duty, with financial limitations being no excuse, even as many states, including Uttar Pradesh, continue to turn a blind eye to these obligations.
The Ground Reality: A Systemic Failure in Infrastructure
The condition of toilets in general is bad, but especially for women toilets where hygiene plays an important role because many have been infected to UTI because of the conditions of the toilet.
In a revealing account of the dire working conditions within the judiciary, Mrs. X, a serving Judicial Officer in Uttar Pradesh, highlights a particularly distressing issue: the lack of access to safe and clean toilets. She describes a situation where the toilets for litigants and judges were located next to each other, directly adjacent to her chamber. This arrangement was not only humiliating but, as a woman, raised significant concerns about safety and hygiene. She expressed hope that the authorities would someday take note of this critical infrastructure failure that compromises the dignity and well-being of those serving the justice system. "The appalling lack of basic sanitation facilities for our judges, especially women judicial officers, is a stark indictment of our system's priorities. When the guardians of justice are denied dignity and safety in their own workplaces, it fundamentally undermines the very integrity of the institution they serve. This is not merely an infrastructural failure, but a profound disrespect for the judiciary itself", said the Judicial Officer from Uttar Pradesh.
We also spoke with Manshi Yadav, an Advocate who regularly appears before courts in Lucknow, Uttar Pradesh. “Navigating the district courts as a practicing advocate means confronting a daily indignity: the complete absence of usable, clean washrooms. The lack of soap and basic sanitation isn't just an inconvenience; it's a serious health hazard. I have personally suffered infections thrice because of these appalling conditions. This neglect reflects a blatant disregard for the health and dignity of every woman, litigant, and professional who is forced to use these facilities", she stated describing the near-impossible challenge of finding a clean toilet within the district courts, noting that basic amenities like soap or proper sanitation are virtually absent. Reflecting on the personal impact of these conditions, she shared that the poor hygiene had directly affected her health, leading to infections on two separate occasions.
“As women in litigation, we are in a constant state of panic when it comes to clean washrooms. Most washrooms in the District Court are either locked, the doors are broken, unclean or the stench is so overbearing that it becomes difficult to even breathe. As for the Raushan-ud-Daula Family Court, unfortunately the washrooms are locked and many lawyers in situations of emergency have to use the Sulabh Sauchalaya washrooms outside. Moreover, we don't find any cleaners around to even raise this concern. It is genuinely very onerous having to worry about safety and sanitation concerns whilst working in the lower courts ” another advocate, Sumedha Sen who regularly appears before the district courts and tribunals said, reflecting that hygiene is a major problem in Uttar Pradesh courts.
A survey of multiple district court complexes across Uttar Pradesh reveals a systemic and chronic failure. Women's toilets are often fewer in number, poorly located, or found locked. Facilities for persons with disabilities, pregnant women, or those with children are virtually non-existent. The state of cleanliness and maintenance is appalling; filthy floors, broken doors, non-functional latches, and clogged drains are commonplace, with overpowering stenches that actively discourage use. The lack of basic amenities is consistent: an absence of running water, soap, and clean towels is a glaring issue. Lighting is frequently poor and ventilation worse, raising serious safety and health concerns. Critically, menstrual hygiene management is entirely overlooked. Sanitary napkin vending machines or disposal incinerators are a rarity, forcing women to manage with improvised and unhygienic methods, stripping them of privacy and bodily dignity.
The Human Cost: Health, Dignity, and Justice Compromised
The impact of this neglect is profound, personal, and gendered. A urinary tract infection is a bacterial infection affecting any part of the urinary system. Poor toilet hygiene—caused by contact with unhygienic surfaces, a lack of water for cleaning, and the inability to maintain personal cleanliness—is a primary risk factor. Multiple women we spoke to reported recurrent UTIs, which they directly attributed to avoiding or using the court toilets. The consequences, however, extend far beyond physical health. There is a deep erosion of dignity, as women are forced to choose between risking their health or enduring immense physical discomfort. This acts as a significant barrier to justice, where litigants, especially from rural areas, may avoid attending court hearings altogether. For female lawyers and staff who spend long hours in court, this is a daily professional hindrance that affects their well-being and efficacy. Vulnerable groups, including elderly women, pregnant litigants, and girl children accompanying parents, face even greater and more distressing hardship.
(District and Sessions Court Complex, Lucknow, Ladies Washroom and one was locked)
(Lakhimpur Kheri, District and Sessions Court Women washroom)
(Bijnour/Bijnore, District and Sessions Court women washroom)
(Nagina, District and Sessions Court womens' washroom)
Family Court, Lucknow Women's Toilet
Conclusion: An Overdue Motion for Dignity
Of the several district courts we accessed across Uttar Pradesh — including those in Lucknow, Barabanki, Lakhimpur Kheri, Bijnor, Gangoh, Ambedkar Nagar, and Bahraich — a stark and unsettling pattern emerged regarding sanitation facilities. In the majority of these locations, the washrooms were in such a state of neglect that the very possibility of a woman finding a clean, usable toilet was remote. The issue extended far beyond mere sanitation; basic provisions like good quality soap or tissue paper were conspicuously absent. These conditions not only create daily discomfort but also pose a significant barrier to dignity and access to justice, particularly for women who spend long hours at the courts.
Amid widespread neglect, the solitary exception of clean toilets in Ambedkar Nagar only underscores the systemic failure across Uttar Pradesh's district courts, where the absence of essential hygiene products like soap and sanitary pads constitutes a profound institutional blindness to women's fundamental needs, forcing a cruel choice between health, dignity, and access to justice. This squalid state is a systemic denial of rights that contradicts the very principles these courts uphold, transforming basic sanitation from a mere amenity into a non-negotiable component of the Right to Life and Access to Justice. Immediate action—including emergency cleaning, mandatory provision of supplies, and gender-sensitive protocols—must be followed by a comprehensive infrastructural overhaul and strict accountability, as true justice cannot be delivered in an environment that degrades half its seekers.
I extend my sincere thanks to my law intern, Vrinda Chaturvedi, a final-year student at Hidayatullah National Law University, and my associate, Manshi Yadav. Their diligent research assistance and unwavering support were instrumental in the completion of this work.
Author is an Advocate practising at the Allahabad High Court and other Courts in Uttar Pradesh. Views Are Personal.