Case at a glance: The Supreme Court has directed the CBI to register a regular criminal case and investigate the death of a man who died while in custody after an arrest under the Chhattisgarh Excise Act. Finding the State officers’ explanations unacceptable and the jail medical report an attempt to mislead, it ordered the State to pay Rs 25 lakh as interim compensation to the widow, with final compensation to be decided later.
The deceased, aged 34, was arrested under Section 34(2) of the Chhattisgarh Excise Act, 1915 on an FIR dated 18 January 2024 for allegedly possessing about six litres of raw Mahua liquor, an offence carrying a maximum of three years. He was remanded to Central Jail, Bilaspur, referred to hospital on 21 January 2024 and died on 22 January 2024. The post-mortem attributed death to complications of a head injury and noted several ante-mortem injuries, while the jail medical report gave a different cause and did not mention the injuries.
A judicial inquiry under Section 176 CrPC reported on 22 July 2024. On 3 October 2024 the Chhattisgarh High Court awarded Rs 1 lakh as compensation but gave no direction for an FIR or investigation. Before the Supreme Court, senior officers including the DGP were directed to appear and did so by video conference on 4 August 2026.
The Key Question Before the Court
Did the facts of this custodial death require registration of an FIR and an independent investigation, and was Rs 1 lakh adequate compensation?
Rejecting the Official Account
The Court found the DGP’s explanation that no case could be registered because the inquiry report had not been received ‘patently false’, since the report was on the High Court’s record. It criticised “the stance of blissful ignorance taken by the senior officers of the State of Chhattisgarh” and described the jail medical account as “a cover-up story and an attempt to pull the wool over the Court’s eyes.”
Given the varying ages of the injuries, the Court said custodial violence over the period of detention could not be ruled out, and that “the facts, therefore, clearly warranted immediate registration of an FIR and a thorough investigation”. In the ends of justice it entrusted the investigation to the CBI, and noting that the State did not dispute that the deceased was the sole breadwinner, it enhanced the relief by way of interim compensation.
What the Court Actually Held
- The Director, CBI must forthwith register a regular case and a senior officer must investigate expeditiously, including the conduct of State officials in handling the inquiry report.
- The DGP, Chhattisgarh must send the complete records to the CBI by special messenger within one week.
- The State must pay Rs 25 lakh as interim compensation to the widow within four weeks.
- Final compensation will be determined when the petition is decided; the matter was listed for 13 October 2026.
Why This Judgment Matters
- It reinforces that a custodial death demands an FIR and independent investigation, not just an inquiry and token compensation.
- It holds senior officers accountable for the handling of inquiry reports.
- It signals that compensation must reflect the loss to dependants.
What Should Advocates Take Away From the Judgment?
For Families and Counsel
- Place the post-mortem report and inquiry findings on record early; contradictions with jail records can be decisive.
- Seek both investigation and compensation; one is not a substitute for the other.
For State Authorities
- Act on judicial inquiry reports without waiting for formal transmission.
- Medical records of prisoners must be complete and consistent with post-mortem findings.
Key Takeaways
- The CBI will investigate the custodial death.
- Rs 25 lakh interim compensation was ordered.
- Officers’ conduct is part of the investigation.
- Final compensation remains to be decided.
Frequently Asked Questions
The Court entrusted the investigation to the CBI in the ends of justice after rejecting the State officers’ explanations.
No. It is interim; final compensation is to be determined later.
Alleged possession of about six litres of raw Mahua liquor under the Chhattisgarh Excise Act.
Conclusion
The order underlines that the State’s obligation after a death in custody is to investigate openly and compensate fairly, not to explain the death away.
Practical takeaway: In custodial death petitions, seek a direction for FIR registration and independent investigation alongside compensation, and test official medical records against the post-mortem.