22 March 2024 FIR >> Criminal Law   |   Investigation >> Criminal Law   |   Murder Homicide >> Criminal Law  

This case involves the death of a 25-year-old woman, Ms. A.S. Reingamphi (hereinafter "the deceased"), found dead in her rented accommodation in Delhi on May 29, 2013. The cause of death remains undetermined despite multiple investigations by local police and a Special Investigation Team (SIT). The deceased's relatives, residing in Manipur, appealed to the Supreme Court of India challenging the Delhi High Court's decision to deny a Central Bureau of Investigation (CBI) inquiry.

Facts:

The deceased's body was discovered by the landlord on May 29, 2013. A post-mortem examination revealed injuries, but the cause of death remained inconclusive. An FIR (First Information Report) was initially filed under Section 306 of the Indian Penal Code (IPC) (abetment to suicide) against unknown persons but later converted to Section 302 IPC (murder). The investigation yielded no concrete results regarding the culprit(s) or the cause of death.

Contentions of the Appellants:

The deceased's relatives, the Appellants, contended that the local police investigation was inadequate and aimed at shielding the accused. They argued that the crime scene suggested a violent act (blood spatter, blood-soaked bedsheet) and suicide was improbable. They sought a thorough investigation by the CBI.

High Court Decision:

The Delhi High Court dismissed the appeal, reasoning that the investigation by the Crime Branch appeared unbiased and there was no evidence implicating the landlord and his brother-in-law, the initial suspects. The court found no exceptional circumstances justifying a CBI inquiry.

Supreme Court's Reasoning:

The Supreme Court, acknowledging the inconclusive investigation, allowed the appeal and directed a CBI inquiry. The court considered the following factors:

• Inconclusive nature of the investigation despite multiple attempts.
• The distance between the deceased's hometown and Delhi, posing logistical challenges for the family.
• The need to restore public trust in the justice system by ensuring a fair and effective investigation.
• Absence of objections from the State regarding a CBI inquiry.

The Court cited precedents emphasizing the discretionary power to order a CBI investigation in exceptional circumstances, particularly when:

• The local investigation appears ineffective.
• Public confidence in the investigation requires bolstering.
• The case involves allegations of serious crimes.

Conclusion:

The Supreme Court's decision highlights the importance of a thorough and effective investigation, particularly when doubts surround the cause of death and the investigation's efficacy. The case demonstrates the court's willingness to intervene and order a CBI inquiry to ensure justice is served.

Indian Penal Code, 1860    

Code of Criminal Procedure, 1973