The Supreme Court, citing investigative bias and procedural lapses by local police, exercised its extraordinary power to transfer the probe to the CBI to ensure a fair and impartial investigation. The Court emphasized that such transfers are exceptional and warranted only in rare circumstances to uphold the rule of law.
Facts Of The Case:
A 17-year-old student, Ms. X, from West Bengal, was preparing for the NEET examination at the Aakash Byju’s Institute in Vishakhapatnam, Andhra Pradesh, and staying at the affiliated Sadhana Ladies Hostel. On the night of July 14, 2023, her father, the appellant, was informed she had fallen from the hostel’s third floor and was taken to Venkataramana Hospital. Despite initially being conscious, her condition deteriorated and she passed away on July 16. Dissatisfied with the local police’s investigation, which hastily concluded the death as a suicide, the appellant alleged a biased probe aimed at shielding the institute and hostel management. He highlighted discrepancies in CCTV footage, alleged medical negligence, and the destruction of key forensic evidence, including the viscera. After the Andhra Pradesh High Court rejected his plea for a CBI investigation, the appellant approached the Supreme Court, arguing the local investigation was perfunctory and aimed at burying the truth, necessitating an independent probe by the central agency.
Procedural History:
The procedural history commenced with the registration of an FIR under Section 174 of the CrPC by the local Andhra Pradesh police. Aggrieved by the investigation, the appellant filed multiple writ petitions before the Andhra Pradesh High Court. The first petition (W.P. No. 20387 of 2023) sought the preservation of evidence, leading to the appointment of an Advocate Commissioner to collect CCTV footage. Subsequently, a second petition (W.P. No. 25381 of 2023) specifically prayed for the transfer of the investigation to the CBI, which was rejected by the High Court in its order dated February 14, 2024. This rejection was then challenged before the Supreme Court through a Special Leave Petition (Cri. No. 6378 of 2024), which granted leave and culminated in the present appeal and judgment.
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Court Observation:
The Court made several critical observations, noting the local investigation was ineffective and highlighted by glaring inconsistencies. It found the unsubstantiated rush to declare the death a suicide, the unexplained discrepancy in the victim’s attire in CCTV footage, and the failure to record her statement while conscious to be deeply problematic. The consolidation of key forensic roles under a single doctor and the premature destruction of visceral evidence were deemed severe lapses that compromised the investigation’s integrity. The Court concluded that these factors, collectively, revealed a prima facie case of bias and institutional failure, creating compelling circumstances that necessitated an extraordinary transfer of the investigation to the CBI to ensure fairness and uphold public confidence in the justice system.
Final Decision & Judgement:
The Supreme Court allowed the appeal and set aside the impugned order of the High Court. The Court directed the immediate transfer of the investigation into the unnatural death of Ms. X to the Central Bureau of Investigation (CBI). The local police were ordered to hand over all case records to the CBI Director, who was to ensure the registration of a Regular Case and assign it to a competent team. The CBI was directed to conclude its investigation and submit a report to the competent court within four months. Additionally, invoking its powers under Article 142 of the Constitution, the Court issued binding interim guidelines to all educational institutions nationwide to implement robust mental health safeguards and suicide prevention mechanisms.
Case Details:
Case Title: Sukdeb Saha vs. The State of Andhra Pradesh & Ors. Citation: 2025 INSC 893 Criminal Appeal No.: (Arising out of SLP (Cri.) No(s). 6378 of 2024) Date of Judgement: July 25, 2025 Judges/Justice Name: Justice Vikram Nath and Justice Sandeep Mehta
Download The Judgement Here