In a recent ruling of Mandakini Diwan and Another v/s The High Court of Chhattisgarh & Others, the Supreme Court has granted leave to appeal regarding the dismissal of a writ petition concerning the suspicious death of Ranjana Diwan, a case that has raised significant questions about the integrity of the investigation conducted by local authorities in Chhattisgarh. The Supreme Court’s decision emphasizes the need for an independent investigation, particularly given the influential position of the deceased's husband, who is a senior judicial officer.
Background of the Case:
The controversy centers on the death of Ranjana Diwan, who was found dead on May 12, 2016. Ranjana, an Assistant District Prosecution Officer, was married to Manvendra Singh, an Additional District Judge. The circumstances surrounding her death have led her family to suspect foul play, especially given the six ante-mortem injuries identified during the post-mortem examination. Following Ranjana's death, her family received no cooperation from local law enforcement, which treated the incident as a straightforward case of suicide. Despite their insistence on a more thorough investigation, their appeals went unheeded, leading to the filing of a writ petition in the High Court of Chhattisgarh in 2016. The petition sought a directive for a fair investigation into Ranjana's death.
High Court's Ruling:
After nearly seven years of pending litigation, the High Court dismissed the petition, citing the availability of statutory remedies under Section 156(3) of the Code of Criminal Procedure (CrPC). The court suggested that the appellants could approach a Magistrate for further action, a recommendation met with skepticism from Ranjana’s family. They argued that given the respondent's influence, they could not expect a fair investigation from local authorities.
Supreme Court's Intervention:
During the appeal, the Supreme Court recognized the family's concerns regarding potential bias in the ongoing investigation. Notably, the Court highlighted the necessity of a credible and independent inquiry, particularly in light of the evidence presented regarding the six ante-mortem injuries and the overall circumstances of the case.
The Solicitor General, representing the Central Bureau of Investigation (CBI), indicated that a CBI investigation could restore public confidence in the judicial process. The Supreme Court ultimately agreed, directing the CBI to conduct a comprehensive and unbiased investigation into Ranjana Diwan's death.
Implications of the Decision:
The Supreme Court's ruling underscores the judiciary's role in ensuring that all allegations of undue influence and bias in criminal investigations are taken seriously. The Court emphasized that unresolved cases not only undermine public trust in law enforcement but also highlight the need for transparency and accountability in the investigation of serious crimes. The order mandates the CBI to thoroughly investigate the case and submit a detailed report, ensuring that if any evidence of foul play arises, appropriate actions will be taken. This decision marks a significant step towards achieving justice for Ranjana Diwan’s family, who have long sought clarity and accountability regarding her tragic death.
