Holding

The Supreme Court held that the extraordinary power to transfer the investigation to the CBI must be exercised in rare and exceptional circumstances, and the present case satisfied those parameters, warranting the transfer.

Summary

The appellant, Sukdeb Saha, challenged the Andhra Pradesh High Court's refusal to transfer the investigation of his 17‑year‑old daughter's suspicious death at a coaching institute to the CBI. He alleged that the local police investigation was biased, incomplete, and that crucial forensic evidence and CCTV footage were mishandled, suggesting a possible cover‑up. The Supreme Court examined the extraordinary power to order a CBI probe, emphasizing that it should be exercised only in rare, exceptional circumstances where fairness, public confidence, and fundamental rights are at stake. Finding multiple inconsistencies—unexplained forensic lapses, contradictory CCTV footage, and the absence of a suicide note—the Court concluded that the local investigation was ineffective and warranted an independent inquiry. Consequently, the Court quashed the High Court order, directed the transfer of the case to the CBI, and issued interim nationwide guidelines for mental‑health safeguards in educational institutions.

Issues considered

The appropriateness of exercising the Court's extraordinary jurisdiction to transfer a criminal investigation to the CBI under Articles 32 and 226 of the Constitution.
Whether the local police investigation into the death of the appellant's daughter was fraught with bias, irregularities, and suppression of evidence justifying CBI intervention.
Whether the right to mental health under Article 21 imposes a duty on educational institutions to adopt preventive measures against student suicides.

Legislation cited

Bharatiya Nagarik Suraksha Sanhita, 2023s. Section 194
Code of Criminal Procedure, 1973s. Section 173(2)
Constitution of Indias. Article 141, s. Article 21, s. Article 32
Indian Penal Code, 1860s. 302, s. 304
Mental Healthcare Act, 2017s. 115, s. 18

Headnote

Issue for Consideration Issue of growing crisis of student suicides in educational institutions; need for a preventive, remedial, and supportive framework for mental health protection and prevention of suicides by students; whether in the facts and circumstances of the case, the High Court erred for transfer of the investigation to the CBI in the suspicious death of his 17-year-old daughter, who was undergoing coaching for NEET examination. Headnotes† Constitution of India – Art.21 – Right to Mental Health – Growing crisis of student suicides – Mental health

Subjects

Article 21 of the Constitution of IndiaMental healthRight to Mental HealthStudent mental healthSuicideStudent suicidesInterim guidelinesBinding guidelinesTransfer of investigation to CBIUnnatural deathSuspicious circumstancesInvestigation into unnatural deathArticle 32 of the Constitution of IndiaArticle 141 of the Constitution of IndiaCoaching for NEETAakash Byju’s Institute, VishakhapatnamSuicide theoryFramework for mental health protectionPrevention of suicides by studentsUMMEED Draft GuidelinesMANODARPANNational Suicide Prevention StrategyChild and adolescent mental healthStudent-to-counsellor ratiosEducational institutionsCoaching institutesResidential institutionsTele-MANASMandatory trainingReporting, redressal, and prevention mechanismsSuicide prevention helplinesPsycho‑social supportSensitisation programmes on student mental healthMental health literacyUndue academic pressureSigns of psychological distressExtracurricular activitiesNational Crime Records BureauReduce academic burdenCareer counselling servicesStudent well‑beingGrievance redressal mechanismsNational Task Force on Mental Health Concerns of Students

Judgment

[2025] 7 S.C.R. 1543 : 2025 INSC 893

Sukdeb Saha
v.
The State of Andhra Pradesh & Ors.
(Criminal Appeal No. 3177 of 2025)
25 July 2025
[Vikram Nath and Sandeep Mehta,* JJ.]

Issue for Consideration
Issue of growing crisis of student suicides in educational
institutions; need for a preventive, remedial, and supportive
framework for mental health protection and prevention of suicides
by students; whether in the facts and circumstances of the
case, the High Court erred in rejecting the appellant’s prayer for
transfer of the investigation to the CBI in the suspicious death
of his 17-year-old daughter, who was undergoing coaching for
NEET examination.

Headnotes†
Constitution of India – Art.21 – Right to Mental Health – Growing
crisis of student suicides – Mental health crisis afflicting
students in educational institutions inter alia, including
schools, coaching institutes, colleges and training centres –
Comprehensive binding interim guidelines issued:
Held: 1.1 All educational institutions to adopt and implement a
uniform mental health policy, drawing cues from the UMMEED
(Understand, Motivate, Manage, Empathise, Empower, and
Develop) Draft Guidelines, the MANODARPAN initiative, and
the National Suicide Prevention Strategy – This policy shall be
reviewed and updated annually and made publicly accessible on
institutional websites and notice boards of the institutes. [Para 35]
1.2 All educational institutions with 100 or more enrolled students
to appoint/engage at least one qualified counsellor, psychologist, or
social worker with training in child and adolescent mental health –
Institutions with fewer students to establish formal referral linkages
with external mental health professionals. [Para 35]

* Author
1544 [2025] 7 S.C.R.

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1.3 Dedicated mentors or counsellors to be assigned to smaller
batches of students, during examination periods and academic
transitions, to provide consistent, informal, and confidential support.
[Para 35]
1.4 All educational institutions to establish written protocols for
immediate referral to mental health services, local hospitals and
suicide prevention helplines – Suicide helpline numbers, including
Tele-MANAS and other national services, shall be prominently
displayed in hostels, classrooms, common areas, and on websites –
All teaching and non-teaching staff to undergo mandatory training
by certified mental health professionals on psychological first-
aid, identification of warning signs, response to self-harm, and
referral mechanisms, at least twice a year – Further guidelines
enumerated – Coaching hubs, including but not limited to Jaipur,
Kota, Sikar, Chennai, Hyderabad, Delhi, Mumbai, and other
cities where students migrate in large numbers for competitive
examination preparation, shall implement heightened mental
health protections and preventive measures – The Department of
Education, District Administration, and management of educational
institutions, to ensure the provision of regular career counselling for
students and parents, regulation of academic pressure planning,
through structured academic availability of continuous psychological
support, and the establishment of institutional mechanisms for
monitoring and accountability to safeguard student mental well-
being. [Para 35]
1.5 These guidelines shall apply to all educational institutions across
India, including public and private schools, colleges, universities,
training centres, coaching institutes, residential academies, and
hostels, irrespective of their affiliation – These guidelines to remain
in force and be binding until appropriate legislation or regulatory
frameworks are enacted by the competent authority and are not
in supersession but in parallel to the ongoing work of the National
Task Force on Mental Health Concerns of Students and are
being issued to provide an interim protective architecture in the
interregnum – These guidelines shall be read as complementary
to the ongoing work of the National Task Force and would inform
and assist the National Task Force in the development of a more
comprehensive and inclusive framework. [Paras 35, 36]
2.1 Directions by Supreme Court – All States and Union Territories
to notify rules within two months from the date of this judgment
[2025] 7 S.C.R. 1545

Sukdeb Saha v. The State of Andhra Pradesh & Ors.

mandating registration, student protection norms, and grievance
redressal mechanisms for all private coaching centres complying
with the mental health safeguards prescribed. [Para 37]
2.2 A district-level monitoring committee to be constituted in each
district under the chairpersonship of the District Magistrate or
Collector – It may include representatives from the departments
of education, health, and child protection, civil society and
shall oversee implementation, conduct inspections, and receive
complaints. [Para 38]
2.3 Union of India to file a compliance affidavit before the Supreme
Court within 90 days from the date of the judgment detailing
the steps taken to implement the guidelines, the coordination
mechanisms established with State Governments, the status of
regulatory rule making w.r.t coaching centres, and the monitoring
systems put in place – The affidavit also to indicate the expected
time line for the completion of the report and recommendations of
the National Task Force on Mental Health Concerns of Students.
[Para 39]

Transfer of investigation to CBI – When warranted – Appellant
filed writ petition seeking transfer of investigation to CBI
following the suspicious death of his 17-year-old daughter,
who was undergoing coaching for NEET examination at
Aakash Byju’s Institute, Vishakhapatnam, after falling from
the terrace of her hostel – Prayer rejected by High Court –
Interference with:
Held: Power to transfer the investigation of a criminal case to the
CBI is an extraordinary measure, which must be exercised with
great caution, and only in rare and exceptional circumstances – This
jurisdiction is not to be invoked lightly or in a routine manner, but
only where the facts of the case disclose a compelling necessity to
ensure fairness in investigation, preservation of public confidence
in the administration of justice, and protection of fundamental
rights of the parties involved – In examining the prayer made by
an aggrieved person seeking transfer of investigation to the CBI,
the Court must necessarily be guided by the strict parameters – In
the present case, the ineffectiveness of the local police officials is
clear and undeniable – The attempt of the respondents to paint the
unfortunate incident as one of suicide, relying upon vague references
to the deceased being “agitated” on the evening of the incident
1546 [2025] 7 S.C.R.

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is wholly unsubstantiated – The original and consistent version
disclosed to the appellant, both by Aakash Institute’s personnel
and local police, was that the appellant’s daughter had fallen from
the terrace – At no point was the suicide theory mentioned to the
appellant – The belated and unsubstantiated narrative of suicide
appears to be a post-facto justification aimed at diluting the gravity
of the incident and shielding institutional lapses – On facts, including
the glaring inconsistencies in the medical records, the autopsy report
indicating suspicious contents of stomach despite the deceased
allegedly being on ventilatory support, the unexplained lapses
in seizure and preservation of critical forensic evidence, and the
contradictory statements by authorities, collectively highlight a case
of exceptional complexity and concern – In view of the rare and
extraordinary circumstances, investigation into the unnatural death
of the appellant’s daughter is transferred to CBI – Impugned order
quashed and set aside. [Paras 19, 21, 21.1, 22-24]
Constitution of India – Arts.21, 32, 141 – Growing crisis
of student suicides – Right to Mental Health, an integral
component of the right to life u/Art.21 – Mental Healthcare
Act, 2017 – ss.18, 115 – 210th Report of Law Commission of
India; statistics in the National Crime Records Bureau in its
2022 report titled “Accidental Deaths and Suicides in India”,
enumerated – India’s obligations under international laws,
discussed – Legislative and regulatory vacuum w.r.t a unified,
enforceable framework for suicide prevention of students –
Binding interim guidelines issued. [Paras 31-35]
Transfer of investigation to CBI – Power to transfer the
investigation of a criminal case to CBI – Parameters to be
considered, stated. [Paras 19, 20]

Case Law Cited
Amit Kumar v. Union of India, 2025 SCC OnLine SC 631; Arnab
Ranjan Goswami v. Union of India [2020] 8 SCR 222 : (2020)
14 SCC 12; State of West Bengal & Others v. Committee for
Protection of Democratic Rights, West Bengal (CPDR) & Others
[2010] 2 SCR 979 : (2010) 3 SCC 571; Shatrughan Chauhan v.
Union of India [2014] 1 SCR 609 : (2014) 3 SCC 1; Navtej Singh
Johar v. Union of India [2018] 7 SCR 379 : (2018) 10 SCC 1;
Vishaka v. State of Rajasthan [1997] Supp. 3 SCR 404 : (1997)
6 SCC 241 – referred to.
[2025] 7 S.C.R. 1547

Sukdeb Saha v. The State of Andhra Pradesh & Ors.

Books and Periodicals Cited
Jean-Jacques Rousseau, “Emile, or Education”, (Ed. and Trans.)
Allan Bloom (New York: Basic Books, 1979); Jiddu Krishnamurti,
“Education and the Significance of Life”, San Francisco, CA: Harper
& Row, 1953; National Crime Records Bureau (NCRB) Chapter-2
Suicides in India Accidental Deaths and Suicides in India, 2022;
Law Commission of India, Report No. 210 on the Humanisation
and Decriminalisation of Attempt to Suicide, Para 1.5 (October
2008); Teasdale, G., & Jennett, B. (1974). Assessment of coma
and impaired consciousness. A practical scale. Lancet (London,
England), 2(7872), 81– 84; Golden, K., Bodien, Y. G., & Giacino, J. T.
(2024). Disorders of Consciousness: Classification and Taxonomy.
Physical medicine and rehabilitation clinics of North America, 35(1),
15–33; Modi JP and others, A Textbook of Medical Jurisprudence
and Toxicology (Lexis Nexis Butterworths Wadhwa Nagpur 2011).

List of Websites
https://ncrb.gov.in/uploads/files/AccidentalDeathsSuicides
inIndia2022v2.pdf.

List of Acts
Mental Healthcare Act, 2017; Penal Code, 1860; Constitution
of India; Bharatiya Nagarik Suraksha Sanhita, 2023; Sexual
Harassment of Women at Workplace (Prevention, Prohibition and
Redressal) Act, 2013.

List of Keywords
Article 21 of the Constitution of India; Mental health; Right to
Mental Health; Student mental health; Suicide; Student suicides;
Interim guidelines; Binding guidelines; Transfer of investigation
to CBI; Unnatural/ Suicide death of a student; Suspicious
circumstances; Investigation into unnatural death; Article 32 of
the Constitution of India; Article 141 of the Constitution of India;
Coaching for the National Eligibility-cum Entrance Test (NEET)
examination; Aakash Byju’s Institute, Vishakhapatnam; Suicide
theory; Theory of suicide; Belated and unsubstantiated narrative
of suicide; Framework for mental health protection; Prevention of
suicides by students across all educational institutions; UMMEED
(Understand, Motivate, Manage, Empathise, Empower, and
Develop) Draft Guidelines for the Prevention of Student Suicide,
1548 [2025] 7 S.C.R.

Supreme Court Reports

2023; MANODARPAN; National Suicide Prevention Strategy;
Child and adolescent mental health; Student-to-counsellor ratios;
Educational institutions; Coaching institutes/centres; Residential-
based institutions; Tele-MANAS; Mandatory training; Mechanisms
for the reporting, redressal, and prevention of incidents; Suicide
prevention helplines; Suicide helpline numbers; Psycho-social
support to victims; Sensitisation programmes on student mental
health; Mental health literacy; Undue academic pressure; Signs
of psychological distress; Extracurricular activities; National Crime
Records Bureau; Reduce academic burden; Career counselling
services; Student mental well-being; Student protection norms;
Grievance redressal mechanisms; Beyond the jurisdiction of
Court; Need for an impartial investigation; Inconsistencies in the
medical records; Lapses in seizure and preservation of critical
forensic evidence; Contradictory statements; Not mere procedural
irregularities; Malaise in the investigational process; National Task
Force on Mental Health Concerns of Students and the Prevention
of Suicides in Higher Educational Institutions; Atma Nirbhar Bharat
Abhiyaan Yojna; National Suicide Prevention Strategy; Ministry of
Health and Family Welfare; International Covenant on Economic,
Social and Cultural Rights; The United Nations Committee on
Economic, Social and Cultural Rights; Convention on the Rights
of Persons with Disabilities, 2006; World Health Organisation’s
Mental Health Action Plan; Comprehensive Mental Health Action
Plan 2013- 2020; Vishaka Guidelines.

Case Arising From
CRIMINAL APPELLATE JURISDICTION: Criminal Appeal No.
3177 of 2025
From the Judgment and Order dated 14.02.2024 of the High Court
of Andhra Pradesh at Amravati in WP No. 25381 of 2023

Appearances for Parties
Advs. for the Appellant:
Joydeb B. Saha, Ayush Mittal, Ms. Oshin Maggu, Zazib Siddiqui,
Gurrick Jassar, Dr. Nb V Srinivasa Reddy, M/s. V. Maheshwari & Co.
Advs. for the Respondents:
Rajkumar Bhaskar Thakare, A.S.G., Mukesh Kumar Maroria, Vivek
Gupta, Rohit Khare, Padmesh Mishra, Merusagar Samantaray,
Tanmay Mehta, Ms. Prerna Singh, Guntur Pramod Kumar, Dhruv
Yadav, P. Santhosh Kumar, Abhiram Bannur, Sravan Kumar
[2025] 7 S.C.R. 1549

Sukdeb Saha v. The State of Andhra Pradesh & Ors.

Karanam, Y. Raja Gopala Rao, Dhuli Gopi Krishna, Akshay Singh,
Ms. Sanjana Jain, Pranav Proothi, Ms. Manasi Chatpalliwar, Pulkit
Agarwal, M Srinivas R Rao, Abid Ali Beeran P, Saswat Adhyapak,
Ms. Namita Kumari, Anand Varma, Ayush Gupta, Kunal Mimani,
Abhinav Rana.

Judgment / Order of the Supreme Court

Judgment

Mehta, J.

Table of Contents*

I. INTRODUCTION ................................................................................ 2
II. PART A: - ........................................................................................... 10
(i). Facts of the Case: - ................................................................ 10
(ii). Submissions on behalf of the Appellant: - ............................ 16
(iii). Submissions on behalf of the Respondents: - ..................... 23
(iv). Discussion & Analysis: - .......................................................... 27
(v). Conclusion: - .............................................................................. 42
III. PART B: ............................................................................................ 44
(i) Background: - ........................................................................... 44
(ii) Right to Mental Health ............................................................. 47
(iii) Guidelines: - ............................................................................. 50
(iv) Directions: - .............................................................................. 59

I. INTRODUCTION

1. Heard.
2. Leave granted.
3. The present appeal arises from the judgment and order dated 14th
February, 2024, passed by the High Court of Andhra Pradesh at
* Ed. Note: Pagination as per the original Judgment.
1550 [2025] 7 S.C.R.

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Amravati1 in Writ Petition No. 25381 of 2023, whereby the High Court
rejected the appellant’s prayer, seeking transfer of the investigation
of FIR No. 148 of 2023 to the Central Bureau of Investigation.2 The
aforesaid FIR was registered following the tragic, unnatural death
of the appellant’s 17-year-old daughter, Ms. X, who was undergoing
coaching for the National Eligibility-cum-Entrance Test (NEET)
examination at Aakash Byju’s Institute, Vishakhapatnam. She was
staying in a Hostel when the unfortunate incident occurred on 14th
July, 2023, leading to her untimely death.
4. Before delving into the factual background and issues of the present
case, this Court deems it appropriate to reflect upon the broader
underlying generational societal issue, namely, the growing crisis
of student suicides in the context of contemporary education. As
articulated by numerous philosophers across history, the purpose
of education was never confined to mere academic success or
professional advancement. Rather, education was envisioned as
a means for holistic development, intellectual, emotional, ethical,
and spiritual. Jean-Jacques Rousseau, in his prominent treatise
“Émile, or On Education”3, emphasised that education must be
adapted to the developmental needs of the child and should cultivate
reason, autonomy, and emotional well-being. He warned against an
educational system that neglects the individuality of the learner in
pursuit of rigid societal expectations.
5. Jiddu Krishnamurti, in his book “Education and the Significance
of Life,”4 noted that the function of education is to create human
beings who are integrated and therefore intelligent. Krishnamurti
cautioned against turning education into a system of conformity
and performance, warning that the mind of a child must not be
conditioned by fear, competition, or compulsion. These philosophical
foundations remind us that education is meant to liberate, not burden
the learner, and that its true success lies not in grades or rankings
but in the holistic growth of a human being capable of living with
dignity, confidence, and purpose.

1 Hereinafter being referred to as ‘Andhra Pradesh High Court’.
2 Hereinafter being referred to as “CBI.”
3 Jean-Jacques Rousseau, “Emile, or Education”, (Ed. and Trans.) Allan Bloom (New York: Basic Books,
1979).
4 Jiddu Krishnamurti, “Education and the Significance of Life”, San Francisco, CA: Harper & Row, 1953.
[2025] 7 S.C.R. 1551

Sukdeb Saha v. The State of Andhra Pradesh & Ors.

6. Contrary to these ideals, the contemporary academic framework,
particularly in the context of competitive examination systems, often
subjects students to relentless psychological pressure. The very soul
of education appears to have been distorted. Increasingly, education
is perceived as a high-stakes race, a pressure-laden path toward
narrowly defined goals of achievement, status, and economic security.
The joy of learning has been replaced by anxiety over rankings,
results, and relentless performance metrics. Students, especially
those preparing for competitive examinations, are often caught in a
web that rewards conformity over curiosity, output over understanding,
and endurance over well-being.
7. In this paradigm, life becomes a series of tests, and failure is seen
not as a part of growth but as a devastating end. In a system driven
by performance metrics, competition, and institutional rigidity, students
are often subjected to immense psychological strain, particularly in
environments geared towards high-stakes competitive examinations.
8. In the recent past, multiple reports have emerged of student suicides
in premier educational institutions and, more particularly, coaching
centres, pointing to a pattern of despair that demands collective
introspection. These young individuals, often far away from home,
isolated in demanding academic environments, find themselves
without adequate emotional or institutional support. The culture of
silence around mental health, coupled with insufficient safeguards in
educational institutions, exacerbates their vulnerability. The gravity
of this crisis cannot be overstated, and any incident involving the
death of a student under such circumstances warrants the utmost
seriousness, not just as an isolated tragedy, but as part of a larger
systemic malaise that threatens the future of the young generation.
9. The statistics published by the National Crime Records Bureau
(‘NCRB’) in its 2022 report titled “Accidental Deaths and Suicides
in India”5 paint a deeply distressing picture. India recorded 1,70,924
reported suicide cases in the year 2022 (an increase from 2021 data,
i.e., 1,64,033 reported suicide cases), of which 7.6%, approximately
13,044, were student suicides. Notably, 2,248 of these deaths were

5 National Crime Records Bureau (NCRB) Chapter-2 Suicides in India Accidental Deaths and Suicides in
India, 2022. Available here. <https://ncrb.gov.in/uploads/files/AccidentalDeathsSuicidesinIndia2022v2.
pdf>.
1552 [2025] 7 S.C.R.

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attributed directly to failure in examinations. As per NCRB data, the
number of suicides among students in the last two decades has
increased from 5,425 in 2001 to 13,044 in 2022. In the decade
beginning from 2012, male student suicides surged to 99% and female
student suicides jumped to 92%. Because of the non-recognition of
transgender/non-binary students in the previous NCRB Reports, the
data of the third gender is totally lacking from the statistics. However,
their underrepresentation should not be disregarded, as it reflects
a systemic failure to acknowledge and address the challenges
faced by transgender and non-binary students within educational
institutions. Needless to say, the abovementioned figures are not
just statistical data, but precious lives lost, young minds prematurely
silenced by pressures they were unable to bear. These figures, taken
in conjunction with emerging patterns of distress in educational
institutions, coaching centres, and residential educational institutions,
point to a systemic failure in addressing students’ emotional and
mental health needs. It must be acknowledged that student suicides,
particularly those related to exam failure, are rarely the result of a
single cause. Multiple factors, both individual and systemic, direct and
indirect, contribute to such outcomes. These include low self-esteem,
unrealistic academic expectations (both self-imposed and externally
driven), impulsivity, social isolation, learning and cognitive disabilities,
and, in some tragic cases, past trauma such as physical or sexual
abuse. Equally concerning are suicides of students precipitated by
experiences of sexual assault, harassment, ragging, bullying, or
discrimination on the basis of caste, gender, sexual orientation, or
disability, which continue to remain underreported and inadequately
addressed. Each of these vulnerabilities may be exacerbated in
high-pressure environments that lack adequate emotional support
and psychological safeguards.
10. The Law Commission of India, in its 210th Report, has recognised
suicide as one of the most tragic and preventable forms of death in
our society.6 This Court has taken judicial notice of the disturbing trend
of suicides among students enrolled in educational institutions, where
intense academic competition often combines with emotional isolation,

6 Law Commission of India, Report No. 210 on the Humanisation and Decriminalisation of Attempt to
Suicide, Para 1.5 (October 2008).
[2025] 7 S.C.R. 1553

Sukdeb Saha v. The State of Andhra Pradesh & Ors.

caste-based discrimination, financial stress, sexual harassment, and
systemic indifference. In Amit Kumar v. Union of India7, this Court
addressed the issue of student suicides across the country and
employed the phrase “suicide epidemic” to describe the alarming
rise of students’ suicide incidents in educational institutions. The
Court observed that a majority of these deaths were attributed to
failure in examinations and the unbearable pressure imposed upon
students by institutional and societal expectations.
11. This Court is therefore of the view that the present case must not
be viewed in isolation, but rather in the context of this deepening
crisis. While the legal and factual question before us concerns the
unnatural/suicide death of a student, the broader social context in
which such cases of suicide occur cannot be ignored.
12. It is in this light that the matter assumes not just legal but also moral,
societal and institutional significance. Accordingly, this judgment
is structured in two parts to address the issues in their entirety.
Part A sets out the factual circumstances of the present case and
adjudicates on the merits of the case. Part B sets out immediate
interim guidelines, aimed at laying down a preventive, remedial, and
supportive framework for mental health protection and prevention of
suicides by students across all educational institutions.

II. PART A: -

(i). Facts of the Case: -
13. The background facts essential for disposal of the instant appeal are:
13.1. The appellant resides in West Bengal with his family. In
May 2022, the appellant’s 17-year-old daughter, Ms. X, took
admission at a coaching institute, namely, Aakash Byju’s Class/
Respondent no. 68 in Vishakhapatnam, Andhra Pradesh, to
prepare for the National Eligibility-cum-Entrance Test (‘NEET’)
examination. She got a rented residential accommodation
in Sadhana Ladies Hostel/Respondent No. 4 9 on the

7 2025 SCC OnLine SC 631.
8 Hereinafter being referred to as “Aakash Institute.”
9 Hereinafter being referred to as “Sadhana Hostel.”
1554 [2025] 7 S.C.R.

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recommendation of Aakash Institute and took admission into
Achiever’s Junior College for Class XII studies, concurrently
pursuing her NEET preparation.
13.2. On 14 th July 2023, at around 11:54 pm, the appellant
received a phone call from Ravikanth, Assistant Branch
Manager (Operations) of Aakash Institute, informing the
appellant that his daughter had fallen from the 3rd floor of
the building of Sadhana Hostel at about 10:20 pm and had
sustained severe injuries and that she had been taken to
Venkataramana Hospital/Respondent No. 5 10 for medical
treatment. The appellant immediately called his daughter’s
friend, who informed him that all the students had been
locked inside a room and that she couldn’t tell what exactly
happened. The appellant’s friend, Bapandas, who hails from
Vishakhapatnam, visited the Venkataramana Hospital on
15th July, 2024, around 1:15 am and found the child, Ms. X,
conscious and talking. The appellant immediately took the
first available flight to Vishakhapatnam (Andhra Pradesh)
and reached the Venkataramana Hospital on 15th July, 2023,
at 1:50 pm, where he found his daughter unconscious and
on ventilator support. The management of Venkataramana
Hospital told the appellant that his daughter had suffered a
heart attack around 4:00 am on 15th July, 2023, but couldn’t
receive proper treatment due to the unavailability of a specialist
medical faculty, and thus, she was placed on a ventilator.
Being dissatisfied with the care and medical treatment being
provided to his daughter at Venkataramana Hospital, the
appellant shifted her to Care Hospital/Respondent No. 711
for better treatment. On 16th July, 2023, approximately 12:00
(noon), the appellant’s daughter, while undergoing medical
treatment, passed away. On the same day, the statement
of the appellant was recorded, and thereafter, an FIR12 was
registered by IV Town Police Station under Section 17413 of

10 Hereinafter referred to as “Venkatramana Hospital.”
11 Hereinafter being referred to as “Care Hospital.”
12 FIR No. 177 of 2023.
13 Corresponding Section 194 of the Bharatiya Nagarik Suraksha Sanhita, 2023.
[2025] 7 S.C.R. 1555

Sukdeb Saha v. The State of Andhra Pradesh & Ors.

the Code of Criminal Procedure.14 Subsequently, an Inquest
Report was prepared on 17th July 2023, and the body of the
deceased was sent for postmortem examination.
13.3. Aggrieved by the suspicious circumstances surrounding the
medical treatment provided to his daughter and dissatisfied
with the authorities’ apparent reluctance to properly investigate
the matter, the appellant approached the Andhra Pradesh High
Court, by way of Writ Petition No. 20387 of 2023 under Article
226 of the Constitution of India, seeking a Writ of Mandamus,
questioning the inaction of the Commissioner of Police and the
SHO in collecting CCTV footage and other material evidence
from Sadhana Hostel, Venkataramana Hospital, and Care
Hospital in relation to the suspicious death of his daughter.
Further, the appellant sought consequential directions for the
appointment of a Court Commissioner to collect the CCTV
footage. The Andhra Pradesh High Court vide Order dated 10th
August 2023, appointed Ms. K. Priyanka Lakshmi as Advocate
Commissioner to collect and verify the CCTV footage for the
period from 1st July, 2023 to 31st July, 2023 in the presence of
the appellant. The above-mentioned Writ Petition was disposed
of by the High Court vide Order dated 12th February, 2024.
13.4. On 20th August 2023, the appellant lodged a formal FIR15 under
Sections 302 and 120 of the Indian Penal Code, 186016, at
Police Station Netaji Nagar, Kolkata, West Bengal, against
Aakash Institute, Sadhana Hostel, and Venkataramana Hospital
and others.
13.5. The Assistant Commissioner of Police17 (East Sub-Division)
Andhra Pradesh, on 27th August 2023, took up the investigation
and, after concluding the same, he filed an Alteration Memo on
29th August 2023, before the Magistrate for applying Section
304 Part-II of the IPC to the case. In this memo, the following
individuals were arrayed as accused persons:-

14 Hereinafter being referred to as “CrPC.”
15 FIR No. 148 of 2023.
16 Hereinafter, being referred to as ‘IPC.’
17 For Short, ‘ACP.’
1556 [2025] 7 S.C.R.

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S. No. Name of the Position
Accused
Accused M.s Gannu Kumari Hostel Warden
No. 1
Accused Yecheral Surya Owner of the Hostel
No. 2 Kumar
Accused Gangumalla Naga Assistant Branch
No. 3 Venkata Durga Manager (Operations)
Ravikanth of Aakash Byju’s
Vishakapatnam
Accused Gundu Rajeshwari Branch Manager
No. 4 Rao of Aakash Byju’s
Vishakapatnam

13.6. On 25th September, 2023, the appellant filed a second Writ
Petition No. 25381 of 2023 under Article 226 of the Constitution
of India, before the Andhra Pradesh High Court, seeking
directions to transfer the investigation of the case to the CBI.
13.7. On 10th November 2023, the appellant filed third Writ Petition
No. 29622 of 2023 under Article 226 of the Constitution of
India, before the Andhra Pradesh High Court, seeking a Writ
of Mandamus, with a declaration that the authorities’ failure to
properly evaluate forensic samples from the deceased’s body
and their classification of the suspicious death as suicide was
illegal, arbitrary, and totally unjustified.
13.8. The Andhra Pradesh High Court, vide Order dated 14 th
February 2024, disposed of the third writ petition by directing
the concerned SHO to send preserved forensic samples of
the deceased, along with samples collected from the appellant
to AIIMS, New Delhi, for DNA testing and determination of
the cause of death, with the entire exercise to be completed
within two months.
13.9. The Andhra Pradesh High Court vide Impugned Order dated
14th February, 2024, disposed of the second Writ Petition
No. 25381 of 2023 and held that since there are two FIRs
registered in two different States i.e., State of Andhra Pradesh
[2025] 7 S.C.R. 1557

Sukdeb Saha v. The State of Andhra Pradesh & Ors.

and State of West Bengal, the prayer seeking transfer of the
case to CBI, was beyond the jurisdiction of the Court.
13.10. The aforesaid order dated 14th February, 2024, of the Andhra
Pradesh High Court is assailed by the appellant in this appeal
with special leave.

(ii). Submissions on behalf of the Appellant: -
14. Learned counsel representing the appellant, vehemently and fervently
urged that the High Court gravely erred in rejecting the prayer of the
appellant, seeking transfer of the case to the CBI. In this regard, he
has advanced the following pertinent submissions:
14.1. The investigation into the unnatural and suspicious death of
the appellant’s daughter, Ms. X, was conducted in a manifestly
arbitrary and perfunctory manner by the local police authorities.
Despite repeated oral and written representations made by
the appellant to the Station House Officer, IV Town Police
Station, Visakhapatnam, seeking registration of an FIR and
fair investigation, the police authorities willfully neglected
their statutory duties. Further, it was submitted that after the
statement of the appellant was recorded on 16th July, 2023,
and inquest proceedings were registered under Section 174
of the CrPC, without conducting proper investigation and
inquiry, the SHO/respondent No. 3 hastily concluded that the
appellant’s daughter had committed suicide. This conclusion
was drawn despite the fact that the appellant was repeatedly
and categorically asserting that his daughter’s death was a
case of unnatural death, warranting investigation under Section
302 of the IPC. The appellant even disclosed the names of
potential accused persons in his statement, yet these leads
were deliberately ignored by the investigating authorities, who
were determined to classify the case as suicide from the outset,
foreclosing any possibility of a proper and fair investigation.
14.2. The doctors and management of Venkataramana Hospital
acted in gross dereliction of their duty by initiating treatment
without informing either the police or the family members, and
by placing the deceased on ventilation without obtaining the
consent of the parents. When the appellant’s daughter, Ms. X,
was admitted to Venkataramana Hospital on 15th July, 2023 at
1558 [2025] 7 S.C.R.

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10:30 pm, she was conscious and even asked for water, as
witnessed at approximately 1:15 am on 16th July, 2023, by the
appellant’s friend namely, Bapandas. Despite her precarious
condition, the doctors and other staff at Venkataramana
Hospital failed to provide proper medical treatment that could
have saved her life. The deceased was in a condition fit
for communication. However, no effort was made by police
authorities to get the statement of Ms. X, which manifests total
apathy on the part of the local authorities.
14.3. The directions issued by the Andhra Pradesh High Court
in Writ Petition No. 20387 of 2023, whereby an Advocate
Commissioner was appointed to secure CCTV footage and
relevant records, were not complied with in the true letter and
spirit. The Advocate Commissioner, appointed by the Andhra
Pradesh High Court, attempted to collect CCTV footage and
documents as directed by the Court vide order dated 10th
August, 2023, but the police officials failed to cooperate fully.
They neither seized the hard disk of the CCTV footage from
the adjacent shop, i.e., Sanghvi Lamination Shop, near which
the incident occurred, nor marked the spot of the incident, nor
collected forensic samples from the said place. The appellant
submits that these material omissions indicate a deliberate
attempt to protect the interests of the respondents, particularly
Aakash Institute, Sadhana Hostel, and Venkataramana Hospital
thereby casting a grave doubt on the bona fides and fairness
of the local police officers.
14.4. The CCTV footage, from Sadhana Hostel shows a girl
in salwar/trousers going upstairs toward the terrace at
approximately 10:25 pm on 14 th July, 2023, whereas the
footage from Sanghvi Lamination Shop from 14th July, 2023,
at 10:46 pm, shows a girl in blue half pants and a T-shirt
lying down on the floor. This glaring discrepancy in apparel
indicates that the girl going upstairs in the hostel footage may
not have been the appellant’s daughter, Ms. X. The police
failed to properly scrutinise and verify the CCTV footage
to confirm the identity of the said girl, yet they have hastily
concluded the case to be one of suicide. These serious lapses
establish beyond doubt that the investigation is neither fair
nor effective.
[2025] 7 S.C.R. 1559

Sukdeb Saha v. The State of Andhra Pradesh & Ors.

14.5. The conduct of senior police officials, including the statement
made by the Police Commissioner during the press conference
on 24th August, 2023, is contrary to the truth and demonstrates
the authorities’ intent to shield the actual culprits. In the press
release, the Commissioner stated that the inquest report was
authored by the appellant’s blood relatives, whereas in reality,
the Circle Inspector of IV Town Police Station dictated the report
and pressured the appellant not to interfere. Furthermore, the
Commissioner’s statement that there was no evidence related
to Aakash Institute is in gross disregard to the fact that the
appellant had enrolled his daughter in Aakash Institute for
competitive exam preparation, and it was on the instruction
and recommendation of the management people from Aakash
Institute that she was accommodated in Sadhana Hostel. As
such, Aakash Institute was the guardian and custodian of Ms.
X and cannot abdicate its responsibility in this matter.
14.6. In the autopsy report dated 17th July, 2023, under column D
(Abdomen), there is explicit mention of a “suspicious smell”
in the stomach contents of the deceased. Despite this finding,
neither the chemical analysis report dated 4th September, 2023,
conducted by Andhra Pradesh Regional Forensic Science
Laboratory18, Visakhapatnam, nor the final opinion on the
cause of death by Autopsy Doctor P. Venkataramana Rao
dated 21st September, 2023, has been procured and placed
on record. The deliberate withholding of these vital forensic
reports strongly suggest an attempt to conceal evidence that
may contradict the theory of suicide hastily advanced by the
investigating authorities.
14.7. The formation and functioning of the Medical Committee
constituted to investigate potential medical negligence suffer
from grave irregularities. While the Superintendent of King
George Hospital, Visakhapatnam, formed a five-member
committee of doctors, strangely enough, Dr. P. Venkataramana
Rao, the autopsy doctor who had already been involved in the
postmortem examination, was also included as a sixth member
without proper notification. This triple role of the said doctor as

18 Hereinafter being referred to as ‘RFSL’.
1560 [2025] 7 S.C.R.

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an autopsy surgeon, chemical analyst, and committee member
represents an egregious conflict of interest and compromises
the independence and integrity of the medical investigation.
Moreover, the Medical Committee itself acknowledged its
limitations, stating in its report that it “has only perused the
documents submitted in the said matter without any interaction
with the doctors who have treated the patient or the relatives of
the deceased,” and that it lacked “knowledge about the medical
facilities, qualifications of treating doctors and infrastructure of
the hospitals where the deceased was treated.”
14.8. The appellant contends that the pathetic failure of the local
police authorities in conducting proper investigation and the
lackadaisical arraignment of certain individuals for criminal
negligence is manifested in the conflicting narratives emerging
from the CCTV footage, medical records, and eyewitness
accounts. It is thus urged that a fair, impartial, and independent
investigation can only be ensured by transferring the matter
to the CBI. The appellant has made several representations
to the State Government for the same, which have remained
unacknowledged. Furthermore, the High Court at Calcutta
in Criminal Revision No. 3541 of 2023 vide Order dated 9th
October 2023, had also stayed the second FIR filed at Police
Station Netaji Nagar, Kolkata, West Bengal.
On these grounds, learned counsel appearing for the appellant
implored the Court to accept this appeal, set aside the
impugned judgment and direct the transfer of the investigation
to the CBI, in the interest of justice and to uphold the rule of law.

(iii). Submissions on behalf of the Respondents: -
15. Per contra, learned counsel for the respondents, vehemently and
fervently opposed the submissions advanced on behalf of the
appellant and advanced the following pertinent submissions imploring
this Court to dismiss the present appeal and reject the prayer to
transfer the investigation to CBI:-
15.1. Investigation into the unfortunate death of the appellant’s
daughter, Ms. X, has been conducted diligently and in
accordance with the law by the local police authorities.
Respondent No. 3, the Investigating Officer, acted promptly
[2025] 7 S.C.R. 1561

Sukdeb Saha v. The State of Andhra Pradesh & Ors.

upon receiving the medico-legal case report (MLC) from
Venkataramana Hospital and recorded the same in the General
Diary. Statements of the attending doctor were recorded, the
scene of the occurrence was inspected, CCTV footage was
reviewed, and over 40 witnesses were examined. Material
evidence, including digital footage, was seized and sent to
the Forensic Science Laboratory (FSL). An offence alteration
memo was filed before the jurisdictional Magistrate based on
emerging evidence to alter the charge to Section 304 Part-II of
the IPC, reflecting the seriousness with which the investigation
has been pursued.
15.2. All necessary medical treatment was rendered to the deceased
in line with standard medical protocols at the Venkataramana
Hospital. The treatment details have been recorded in the
case sheet, and the patient was referred to another Hospital
i.e., Care Hospital, only after due consultation and with the
appellant’s consent. The allegations that the hospital failed
in its duty of care and proper treatment are baseless. The
CCTV footage in question was seized by the authorities and
forwarded for forensic recovery; however, due to automatic
overwriting, certain footage could not be retrieved directly by
the Venkataramana Hospital. Nevertheless, full cooperation
was extended to the Advocate Commissioner during the inquiry
proceedings.
15.3. The appellant is attempting to attribute vicarious liability to
Aakash Institute without any legal or factual basis. The said
Institute was only responsible for academic instructions and had
no control or supervisory role over hostel accommodation. The
deceased was residing in Sadhana Hostel, chosen voluntarily
by her family members. Two employees of Sadhana Hostel,
who were arrested, have since been enlarged on bail, as the
High Court found no evidence connecting them to the incident.
15.4. There was no medical negligence or misconduct on the part
of Care Hospital. When the deceased was admitted in the
said facility, no discharge summary or medical records were
provided to the Hospital. Despite the patient arriving in a critical,
vegetative state, all necessary steps were taken to revive
her. Care Hospital has placed all medical records before the
1562 [2025] 7 S.C.R.

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competent authorities and cooperated fully with the Advocate
Commissioner.
15.5. It is submitted that mere dissatisfaction or suspicion on the
part of the complainant does not constitute a valid ground
to invoke the extraordinary jurisdiction of this Court so as to
transfer the investigation to the CBI. It has been consistently
held by this Court that such power must be exercised sparingly
and only in rare and exceptional cases where there is clear
evidence of bias, mala fide intent, or deliberate inaction on
the part of the investigating agency. Learned counsel in this
regard has placed reliance upon the decision of this Court in
the cases of Arnab Ranjan Goswami v. Union of India19
to urge that in the present case, no such material has been
placed on record to even create a doubt that the ongoing
investigation suffers from institutional bias or legal infirmity
so as to warrant intervention.
On these grounds, the learned counsel for the respondents
implored the Court to dismiss the present appeal and affirm
the judgment of the High Court.

(iv). Discussion & Analysis: -
16. We have given our thoughtful consideration to the submissions
advanced at the bar and have gone through the impugned judgment.
With the assistance of the learned counsel for the parties, we have
perused the material placed on record.
17. At the outset, we may like to note that the power to transfer an
investigation to the CBI is not to be exercised as a matter of course.
This Court has consistently held that such a course of action is
exceptional and the extraordinary jurisdiction should be invoked to this
end only in rare and compelling circumstances where the interest of
justice so demands. A Constitution Bench in State of West Bengal &
Others v. Committee for Protection of Democratic Rights, West
Bengal (CPDR) & Others20, examined the circumstances under
which Constitutional Courts may invoke their jurisdiction to direct a

19 (2020) 14 SCC 12.
20 (2010) 3 SCC 571.
[2025] 7 S.C.R. 1563

Sukdeb Saha v. The State of Andhra Pradesh & Ors.

CBI investigation. The Court held that such extraordinary jurisdiction
may be invoked to ensure a fair and impartial investigation where
State machinery appears to be ineffective, biased, or complicit. The
relevant paragraph of the judgment is extracted below:
“70. Before parting with the case, we deem it necessary to
emphasise that despite wide powers conferred by Articles
32 and 226 of the Constitution, while passing any order, the
Courts must bear in mind certain self-imposed limitations
on the exercise of these constitutional powers. The very
plenitude of the power under the said articles requires
great caution in its exercise. Insofar as the question of
issuing a direction to CBI to conduct investigation in
a case is concerned, although no inflexible guidelines
can be laid down to decide whether or not such power
should be exercised but time and again it has been
reiterated that such an order is not to be passed as
a matter of routine or merely because a party has
levelled some allegations against the local police.
This extraordinary power must be exercised sparingly,
cautiously and in exceptional situations where it
becomes necessary to provide credibility and instil
confidence in investigations or where the incident
may have national and international ramifications
or where such an order may be necessary for doing
complete justice and enforcing the fundamental
rights. Otherwise CBI would be flooded with a large
number of cases and with limited resources, may find
it difficult to properly investigate even serious cases
and in the process lose its credibility and purpose with
unsatisfactory investigations.”
(Emphasis Supplied)

18. This Court in the case of Arnab Ranjan Goswami v. Union of India
(supra), held that:
“52. [.]. An individual under investigation has a legitimate
expectation of a fair process which accords with law. The
displeasure of an accused person about the manner in
which the investigation proceeds or an unsubstantiated
1564 [2025] 7 S.C.R.

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allegation (as in the present case) of a conflict of interest
against the police conducting the investigation must
not derail the legitimate course of law and warrant the
invocation of the extraordinary power of this Court to
transfer an investigation to CBI. Courts assume the
extraordinary jurisdiction to transfer an investigation in
exceptional situations to ensure that the sanctity of the
administration of criminal justice is preserved. While no
inflexible guidelines are laid down, the notion that such a
transfer is an “extraordinary power” to be used “sparingly”
and “in exceptional circumstances” comports with the idea
that routine transfers would belie not just public confidence
in the normal course of law but also render meaningless
the extraordinary situations that warrant the exercise of
the power to transfer the investigation. .[.].”
19. The settled principle of law that emerges from the abovementioned
decisions is that the power to transfer the investigation of a criminal
case to the CBI is an extraordinary measure, which must be exercised
with great caution, and only in rare and exceptional circumstances.
This jurisdiction is not to be invoked lightly or in a routine manner, but
only where the facts of the case disclose a compelling necessity to
ensure fairness in investigation, preservation of public confidence in
the administration of justice, and protection of fundamental rights of
the parties involved. In examining the prayer made by an aggrieved
person seeking transfer of investigation to the CBI, the Court must
necessarily be guided by the strict parameters laid down in binding
precedents.
20. These parameters inter alia include, instances where the State police
authorities appear to be biased or complicit, where the investigation
has been tainted by delay, irregularity, or suppression of material
facts, or where the complexity and inter-state ramifications of the
matter necessitate the involvement of a central agency.
21. In the present case, while we refrain from commenting on the fairness
of the investigation conducted thus far, the ineffectiveness of the
local police officials is clear and undeniable. The following compelling
factors, when considered together, conclusively demonstrate the
failure of the local investigation and highlight the imminent need for
an impartial investigation by the CBI:
[2025] 7 S.C.R. 1565

Sukdeb Saha v. The State of Andhra Pradesh & Ors.

21.1. The attempt of the respondents to paint the unfortunate
incident as one of suicide, relying upon vague references to
the deceased being “agitated” on the evening of 14th July,
2023, is wholly unsubstantiated. The original and consistent
version disclosed to the appellant, both by Aakash Institute’s
personnel and local police, was that the appellant’s daughter
had fallen from the terrace. At no point was the suicide
theory mentioned to the appellant in real time, either orally or
through any written communication. It is only in hindsight that
respondents have sought to paint the deceased as mentally
perturbed. If this was truly a case of suicide, it is inexplicable
that no suicide note was recovered, no psychological history
was documented, and no statements of her friends, classmates
or roommates were recorded to establish any alleged suicidal
tendencies. Moreover, no medical or psychiatric records have
been produced to support such a claim. The belated and
unsubstantiated narrative of suicide appears to be a post-facto
justification aimed at diluting the gravity of the incident and
shielding institutional lapses.
21.2. A description of the CCTV footage collected by the Advocate
Commissioner (in the report) reveals glaring contradictions that
remain unaddressed by the investigating agency. The footage
from Sadhana Hostel shows a girl walking up the stairs at
around 10:25 pm on 14th July 2023, wearing a salwar/trousers
and a T-shirt. In stark contrast, the footage of around 10:46
pm from the adjacent building, i.e., Sanghvi Lamination shop,
which allegedly captures the fall, shows a girl dressed in blue
half-pants and a t-shirt. This fundamental inconsistency has
not been reconciled by the Investigating Officers. No attempt
whatsoever has been made to verify whether the girl who
was seen going upstairs was none other than the deceased
(Ms. X) who was found lying on the floor. No forensic/DNA
analysis or witness identification has been attempted. This
discrepancy severely undermines the credibility of the claim
that the deceased herself went upstairs and jumped off the
terrace.
21.3. The respondents’ claim that the young girl (Ms. X) was in an
irreversible critical state from the moment of the fall stands
completely contradicted by their own records, the AIIMS
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Medical Board Report, and independent evidence on record.
While the Investigation Officer, Sadhana Hostel and the
Venkataramana Hospital have categorically taken a stand
that the young girl (Ms. X) was unconscious when brought
to the hospital, the AIIMS Medical Board has clearly noted
that the young girl (Ms. X) was admitted to the hospital in a
conscious and irritable state, with a Glasgow Coma Scale
(GCS) score of 10/15, indicating that she was neurologically
responsive at the time of admission. This observation of the
AIIMS Medical Board is further corroborated by the statement
of the appellant, who stated that at approximately 1:15 am on
15th July, 2023, his friend saw the young girl (Ms. X) moving
and verbally asking for water, a clear indication of retained
consciousness and lucidity. Despite this, when the appellant
arrived at Venkataramana Hospital later that day, he found
that his daughter was placed on a ventilator. No consent,
written or oral, was obtained from the appellant, any family
member, or a responsible person prior to this critical medical
intervention. Furthermore, at no point was the appellant or
even his friend, who was physically present in Visakhapatnam,
informed about the occurrence of a heart attack or deterioration
of Ms. X’s condition during the night. If the deceased was
indeed conscious, there was sufficient time and opportunity
to record her statement, which would have been crucial in
uncovering the circumstances surrounding the incident. The
failure to do so, despite the documented conscious state of
Ms. X, reflects not only gross medical negligence but also a
possible suppression of key evidence that could have aided
the unravelling of the truth.
21.4. A deeply troubling and questionable aspect of the present
case is the consolidation of three critical forensic roles with
the same medical officer (namely, Dr P. Venkata Ramana Rao)
who functioned simultaneously as the autopsy surgeon while
conducting post-mortem examination, chemical analyst for
forensic/DNA examination and a member of the post-incident
internal inquiry committee. Each of these roles, by the very
nature of their functions, require institutional independence,
objectivity, and professional detachment. There appears to
be no justification for inclusion of the autopsy surgeon in all
[2025] 7 S.C.R. 1567

Sukdeb Saha v. The State of Andhra Pradesh & Ors.

these roles, which create a great deal of doubt in the mind
of the Court.
21.5. The premature destruction of the deceased’s viscera, ordinarily
the cornerstone of any postmortem DNA comparison, before
completing the court-mandated investigation, has irrevocably
compromised the proceedings. Acting on the High Court’s
order dated 14th February, 2024, in W.P. No. 29622 of 2023,
the (then) ACP (East)/IO, Visakhapatnam, wrote to RFSL,
Visakhapatnam, on 24th February, 2024, to confirm whether
the viscera he had sent on 16th August, 2023, remained
preserved after chemical analysis. RFSL, Visakhapatnam
acknowledged the receipt of the viscera and assured to issue a
written reply on 26th February, 2024. Anticipating that response,
the ACP (East)/IO collected the appellant’s blood sample on
25th February, 2024, at King George Hospital, sealed it in a
thermocol box and documented the process with photographs
and video. However, RFSL, Visakhapatnam, vide letter dated
26th February, 2024, informed the ACP that it had destroyed
the viscera “after analysis,” citing the IO’s note in the Letter
of Advice that preservation was “not necessary.” By failing to
ensure the preservation of this critical forensic material before
securing the DNA match ordered by the High Court, the ACP
and RFSL have undermined the investigation’s integrity and
foreclosed any possibility of conclusively establishing the
cause of death.
21.6. In the autopsy report dated 17th July, 2023, under Column D
(Abdomen), it has been explicitly recorded that approximately
80 grams of semi-digested rice like brown, yellow, and white
coloured food particles were present in the stomach contents of
the deceased, along with a “suspicious smell.” This observation
assumes critical importance when juxtaposed with the fact that
Ms. X was allegedly placed on a ventilator from the early hours
of 15th July, 2023, and remained in an unconscious/vegetative
state until her demise on 16th July, 2023. The presence of
semi-digested food in the stomach, as noted in the autopsy
report, is irreconcilable with the claim that the deceased was on
continuous ventilatory support from the early hours of 15th July,
2023. Under normal conditions, solid foods get digested and
move from the stomach to the intestine within approximately
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2½ to 6 hours, with carbohydrate-rich meals leaving even
sooner; liquids pass almost immediately. In a state of shock
or coma, gastric motility is markedly impaired, often delaying
emptying of the stomach far beyond the normal window, but
cannot leave a “suspicious smell” and undigested rice nearly
48 hours later.21 There is no accepted protocol for feeding solid
rice to a patient on mechanical ventilation. This stark mismatch
between Ms. X’s autopsy/viscera’s report and the hospital’s
narrative strongly suggests that either the ventilator timeline
was misrepresented or additional, and yet undisclosed, events
occurred after the last proper meal taken by Ms. X.
21.7. In particular, two documents of foundational evidentiary
value, the Chemical Analysis Report of the viscera and the
final opinion on the cause of death, have not been placed on
record. These documents are not ancillary but form the core
forensic backbone of any investigation into unnatural death.
The Chemical Analysis Report, for instance, could conclusively
determine whether the deceased was administered poison,
sedatives, or any narcotic agent that may have contributed
to her fall from the terrace or deterioration of her vitals. The
final cause of death report is essential for understanding
whether death was a result of accidental trauma, deliberate
assault, or complications arising from medical intervention.
The appellant has made multiple attempts, both personally
and through counsel, to obtain copies of these documents.
Even the Advocate Commissioner appointed by the High Court
noted during the site visits and interactions that these records
were not handed over, either to the Commissioner herself or
to the appellant’s representatives. The resistance exhibited by
the respondents in providing such critical information cannot
be viewed as a mere administrative lapse and creates a grave
doubt on the bona fides of their actions.
21.8. Furthermore, the assessment conducted by the Medical Board
constituted at the All-India Institute of Medical Sciences (AIIMS),
New Delhi, a premier and impartial medical authority, lends

21 Modi JP and others, A Textbook of Medical Jurisprudence and Toxicology (Lexis Nexis Butterworths
Wadhwa Nagpur 2011).
[2025] 7 S.C.R. 1569

Sukdeb Saha v. The State of Andhra Pradesh & Ors.

significant weight to the appellant’s contentions. The Board,
after a detailed examination of the submitted medical records
and documents, found that the deceased was admitted to
Venkataramana Hospital in a conscious and irritable state,
with a Glasgow Coma Scale E3V2M5-Score of 10/15. The
Glasgow score, which is scored between 3 and 15 (Score 3
being the worst, and Score 15 being the best) is internationally
recognised as an indicator of a patient’s neurological activity. A
score in this range suggests that the patient was neurologically
active and semi-alert, and not comatose at the time of hospital
admission.22 The deceased had sustained multiple severe
grade injuries, including traumatic brain injury, pneumothorax,
skull fractures, and fractures of the spine, pelvis, and limbs.
These findings confirm that the deceased was critically
injured but was not beyond the scope of meaningful medical
intervention. Importantly, the AIIMS Medical Board observed
that the patient’s condition deteriorated over time, ultimately
dropping to a Glasgow Coma Scale E1VTM1-Score of 3/15,
suggesting that a medical or neurological failure occurred
during hospitalisation. The Board explicitly stated that while it
could not opine definitively on medical negligence owing to lack
of access to the treating doctors and hospital infrastructure, its
observations were strictly based on objective documentation.
22. The foregoing facts and circumstances, including the glaring
inconsistencies in the medical records, the autopsy report indicating
suspicious contents of stomach despite the deceased allegedly
being on ventilatory support, the unexplained lapses in seizure
and preservation of critical forensic evidence, and the contradictory
statements by authorities, collectively highlight a case of exceptional
complexity and concern. These elements are not indicative of mere
procedural irregularities but point towards a potentially deeper
malaise in the investigational process. In such a situation, it becomes
imperative to ensure that the sanctity of the administration of justice
is preserved, and public confidence is upheld. Criminal investigation
must, in all circumstances, be both fair and effective to uphold the

22 Teasdale, G., & Jennett, B. (1974). Assessment of coma and impaired consciousness. A practical scale.
Lancet (London, England), 2(7872), 81–84. Also See, Golden, K., Bodien, Y. G., & Giacino, J. T. (2024).
Disorders of Consciousness: Classification and Taxonomy. Physical medicine and rehabilitation clinics
of North America, 35(1), 15–33.
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rule of law. It is in these rare and extraordinary circumstances that
the intervention of this Court is warranted, and the transfer of the
investigation to the CBI becomes not only justified but essential.
23. The appellant and the other family members of the deceased,
who reside in West Bengal, face substantial logistical and practical
barriers in engaging with the authorities in Visakhapatnam, Andhra
Pradesh. Yet, they have persistently sought justice, showing faith in
the constitutional system and legal process. In light of the constant
and deliberate non-cooperation by the local authorities, contradictory
public statements by police officials, and allegations of suppression
of material evidence, this Court is of the considered view that the
investigation into the unnatural death of Ms. X has to be entrusted
to the CBI. Such a transfer is necessary not only to ensure a
comprehensive and impartial investigation but also to restore public
confidence and address the legitimate concerns of the bereaved
family, and ultimately, to ensure that the actual perpetrators of the
crime, if any, are brought to justice.

(v). Conclusion: -
24. In view of the above discussion, the Impugned Order dated 14th
February, 2024, passed by the High Court of Andhra Pradesh in
Writ Petition No. 25381 of 2023, rejecting the appellant’s prayer for
transfer of investigation to the CBI, is hereby quashed and set aside.
25. We direct that the investigation into the unnatural death of Ms. X
shall be transferred to the CBI forthwith. The Investigating Officer and
concerned authorities of the IV Town Police Station, Visakhapatnam,
shall hand over the entire case records, including all relevant papers,
documents, CCTV footage, forensic reports, and any material
evidence, to the office of Director, CBI without undue delay. T h e
Director, CBI, shall ensure the immediate registration of an RC and
assign the investigation of the same to a team of competent officials
under the supervision of the jurisdictional Superintendent, CBI.
26. We clarify that the observations made above are not intended to
touch the merits of the case at hand, and they shall have no bearing
on the investigation conducted by the CBI or the trial, as the case
may be. None of the above observations shall prejudice the defence
of the person/s, who may be arrayed as an accused in this case.
The concerned officials of CBI shall conduct an extensive and
[2025] 7 S.C.R. 1571

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comprehensive investigation into the matter and, upon conclusion,
submit a report under Section 193(2) of the Bharatiya Nagarik
Suraksha Sanhita, 202323, before the competent Court having
jurisdiction, within four months from the date of receiving the record.

III. PART B:

(i) Background: -
27. Considering the above factual circumstances and the foregoing
situation of an increasing number of suicides in educational
institutions, inter alia, including schools, coaching institutes, colleges,
and training centres, we feel obliged to acknowledge and address the
gravity of the mental health crisis afflicting students in educational
institutions across the country. The continued loss of young lives,
often due to preventable causes rooted in unattended psychological
distress, academic overburden, social stigma, and institutional
insensitivity, reflect a systemic failure that cannot be ignored. The
above-mentioned data24, as reported in the National Crime Records
Bureau, reveal a distressing pattern of rising student suicides.
28. The Union Government, so far, has taken several preventive
steps to check and correct the situation. At the school level, the
UMMEED (Understand, Motivate, Manage, Empathise, Empower,
and Develop) Draft Guidelines for the Prevention of Student Suicide
were released by the Ministry of Education in 2023. These guidelines
aim to sensitise schools, identify students at risk, and provide
institutional responses and community-based interventions. For a
broader reach, the Ministry of Education launched MANODARPAN,
mental health and well-being of students during the COVID-19
pandemic and beyond, under the Atma Nirbhar Bharat Abhiyaan
Yojna, providing tele-helplines, live sessions with counsellors, a
directory of trained professionals, and digital content to promote
emotional well-being. Likewise, the National Suicide Prevention
Strategy, released by the Ministry of Health and Family Welfare in
2022, outlines a multi-sectoral approach towards suicide prevention
with a specific focus on youth.

23 Formerly, Section 173(2) of the CrPC.
24 Refer to Para 9 of this Judgment.
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29. Recently, taking cognizance of the suicide epidemic in educational
institutions, this Court in Amit Kumar (supra), directed the constitution
of a National Task Force on Mental Health Concerns of Students
and the Prevention of Suicides in Higher Educational Institutions,
under the chairpersonship of Hon’ble Justice (Retd.) Shri Ravindra
Bhat. The Task Force includes eminent experts from psychiatry, child
development, education, public health, and civil society, and has
been entrusted with identifying the root causes of student suicides,
evaluating the effectiveness of current policies, and recommending
institutional and regulatory reforms. We have been informed that the
Task Force has convened its first and second meetings, constituted
working groups, and is in the process of gathering inputs from
stakeholders to formulate a robust and comprehensive framework.
30. While the final report of the Task Force is awaited, and the framework
is under preparation, the immediacy of the crisis demands immediate
institutional safeguards to prevent further loss of life and to establish
accountability criterion. In such a context, the Court is not only
empowered but constitutionally obligated to step in.

(ii) Right to Mental Health
31. Mental health is an integral component of the right to life under Article
21 of the Constitution of India. This Court has, in a consistent line of
precedents, affirmed that the right to life does not mean mere animal
existence, but a life of dignity, autonomy, and well-being. Mental health
is central to this vision. In Shatrughan Chauhan v. Union of India25
and Navtej Singh Johar v. Union of India26, this Court recognised
mental integrity, psychological autonomy, and freedom from degrading
treatment as essential facets of human dignity under Article 21 of
the Constitution of India. Further, the Mental Healthcare Act, 201727,
a rights-based legislation, reinforces this constitutional mandate by
recognising every person’s right to access mental healthcare and
protection from inhuman or degrading treatment in mental health
settings. Section 18 of the MH Act guarantees mental health services
to all, and Section 115 of the MH Act explicitly decriminalises attempted

25 (2014) 3 SCC 1.
26 (2018) 10 SCC 1.
27 Hereinafter referred to as MH Act.
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suicide, acknowledging the need for care and support rather than
punishment. These provisions read with judicial precedents reflect
a broader constitutional vision that mandates a responsive legal
framework to prevent self-harm and promote well-being, particularly
among vulnerable populations such as students and youth.
32. Under International Law, India’s obligations under various human
rights instruments and treaties reinforce the above constitutional
imperative to protect and promote mental health. The International
Covenant on Economic, Social and Cultural Rights, to which India
is a State Party, under Article 12 recognises the right to the highest
attainable standard of physical and mental health. The United Nations
Committee on Economic, Social and Cultural Rights, in its General
Comment No. 14, has affirmed that this right includes timely access
to mental health services and prevention of mental illness, including
suicide. Similarly, under the Convention on the Rights of Persons with
Disabilities, 2006, mental health conditions are recognised within the
scope of psychosocial disabilities, and States are under an obligation
to provide accessible, non-discriminatory mental health care to the
vulnerable individuals. Further, the World Health Organisation’s Mental
Health Action Plan, such as the WHA66.8 Comprehensive Mental
Health Action Plan 2013-2020, have identified suicide prevention as
a public health priority, calling upon States to reduce suicide mortality
rates through national strategies, school-based interventions, and
community support mechanisms. These evolving international norms
reinforce the view that suicide prevention is not merely a policy
objective but a binding obligation flowing from the right to life, health,
and human dignity.
33. Despite these constitutional and international obligations, there
remains a legislative and regulatory vacuum in the country with respect
to a unified, enforceable framework for suicide prevention of students
in educational institutions, coaching centres, and student-centric
environments. Given the pressing nature of the crisis, particularly in
cities like Kota, Jaipur, Sikar, Vishakhapatnam, Hyderabad, and Delhi
(NCR), etc., where students migrate in large numbers for competitive
examinations and face intense psychological pressure, immediate
interim safeguards are the call of the day.
34. This Court has, in the past, experienced a similar vacuum in
matters concerning sexual harassment of women in the workplace.
Recognising the urgent need for institutional safeguards, this Court,
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in Vishaka v. State of Rajasthan28, laid down guidelines and norms
under Article 141 of the Constitution of India, which came to be
known as the celebrated ‘Vishaka Guidelines.’ These guidelines and
norms subsequently formed the basis of statutory enactment in the
form of the Sexual Harassment of Women at Workplace (Prevention,
Prohibition and Redressal) Act, 2013.

(iii) Guidelines: -
35. Keeping in view of the above, and in exercise of the powers conferred
upon this Court under Article 32 of the Constitution of India for the
enforcement of fundamental rights, and treating this pronouncement
as law declared by this Court under Article 141, we hereby issue the
following guidelines, which shall remain in force and be binding until
such time as appropriate legislation or regulatory frameworks are
enacted by the competent authority. The Guidelines are prescribed
as under:
I. All educational institutions shall adopt and implement a uniform
mental health policy, drawing cues from the UMMEED Draft
Guidelines, the MANODARPAN initiative, and the National
Suicide Prevention Strategy. This policy shall be reviewed and
updated annually and made publicly accessible on institutional
websites and notice boards of the institutes.
II. All educational institutions with 100 or more enrolled students
shall appoint/engage at least one qualified counsellor,
psychologist, or social worker with demonstrable training in
child and adolescent mental health. Institutions with fewer
students shall establish formal referral linkages with external
mental health professionals.
III. All educational institutions shall ensure optimal student-to-
counsellor ratios. Dedicated mentors or counsellors shall be
assigned to smaller batches of students, especially during
examination periods and academic transitions, to provide
consistent, informal, and confidential support.
IV. All educational institutions, more particularly the coaching
institutes/centres, shall, as far as possible, refrain from engaging
in batch segregation based on academic performance, public

28 (1997) 6 SCC 241.
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shaming, or assignment of academic targets disproportionate
to students’ capacities.
V. All educational institutions shall establish written protocols for
immediate referral to mental health services, local hospitals,
and suicide prevention helplines. Suicide helpline numbers,
including Tele-MANAS and other national services, shall be
prominently displayed in hostels, classrooms, common areas,
and on websites in large and legible print.
VI. All teaching and non-teaching staff shall undergo mandatory
training at least twice a year, conducted by certified mental
health professionals, on psychological first-aid, identification of
warning signs, response to self-harm, and referral mechanisms.
VII. All educational institutions shall ensure that all teaching,
non-teaching, and administrative staff are adequately trained
to engage with students from vulnerable and marginalised
backgrounds in a sensitive, inclusive, and non-discriminatory
manner. This shall include, but not be limited to, students
belonging to Scheduled Castes (SC), Scheduled Tribes (ST),
Other Backward Classes (OBC), Economically Weaker Sections
(EWS), LGBTQ+ communities, students with disabilities, those in
out-of-home care, and students affected by bereavement, trauma,
or prior suicide attempts, or intersecting form of marginalisation.
VIII. All educational institutions shall establish robust, confidential,
and accessible mechanisms for the reporting, redressal, and
prevention of incidents involving sexual assault, harassment,
ragging, and bullying on the basis of caste, class, gender, sexual
orientation, disability, religion, or ethnicity. Every such institution
shall constitute an internal committee or designated authority
empowered to take immediate action on complaints and provide
psycho-social support to victims. Institutions shall also maintain
zero tolerance for retaliatory actions against complainants or
whistle-blowers. In all such cases, immediate referral to trained
mental health professionals must be ensured, and the student’s
safety, physical and psychological, shall be prioritised. Failure to
take timely or adequate action in such cases, especially where
such neglect contributes to a student’s self-harm or suicide, shall
be treated as institutional culpability, making the administration
liable to regulatory and legal consequences.
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IX. All educational Institutions shall regularly organise sensitisation
programmes (physical and/or online) for parents and guardians
on student mental health. It shall be the duty of the institution
to sensitise the parents and guardians to avoid placing undue
academic pressure, to recognise signs of psychological
distress, and to respond empathetically and supportively.
Further, mental health literacy, emotional regulation, life skills
education, and awareness of institutional support services
shall be integrated into student orientation programmes and
co-curricular activities.
X. All educational institutions shall maintain anonymised records
and prepare an annual report indicating the number of wellness
interventions, student referrals, training sessions, and mental
health-related activities. This report shall be submitted to the
relevant regulatory authority, which may be the State Education
Department, University Grants Commission (UGC), All India
Council for Technical Education (AICTE), Central Board of
Secondary Education (CBSE), or as otherwise indicated.
XI. All educational institutions shall prioritise extracurricular
activities, including sports, arts, and personality development
initiatives. Examination patterns shall be periodically reviewed
to reduce academic burden and to cultivate a broader sense of
identity among students beyond test scores and ranks.
XII. All educational institutions, including coaching centres and
training institutes, shall provide regular, structured career
counselling services for students and their parents or guardians.
These sessions shall be conducted by qualified counsellors and
shall aim to reduce unrealistic academic pressure, promote
awareness of diverse academic and professional pathways, and
assist students in making informed and interest-based career
decisions. Institutions shall ensure that such counselling is
inclusive, sensitive to socio-economic and psychological contexts,
and does not reinforce narrow definitions of merit or success.
XIII. All residential-based educational institutions, including hostel
owners, wardens and caretakers, shall take proactive steps to
ensure that campuses remain free from harassment, bullying,
drugs, and other harmful substances, thereby ensuring a safe
and healthy living and learning environment for all students.
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XIV. All residential-based institutions shall install tamper-proof ceiling
fans or equivalent safety devices, and shall restrict access to
rooftops, balconies, and other high-risk areas, in order to deter
impulsive acts of self-harm.
XV. All coaching hubs, including but not limited to Jaipur, Kota,
Sikar, Chennai, Hyderabad, Delhi, Mumbai, and other cities
where students migrate in large numbers for competitive
examination preparation, shall implement heightened mental
health protections and preventive measures. These regions,
having witnessed disproportionately high incidents of student
suicides, require special attention. The concerned authorities,
namely, the Department of Education, District Administration,
and management of educational institutions, shall ensure the
provision of regular career counselling for students and parents,
regulation of academic pressure through structured academic
planning, availability of continuous psychological support, and
the establishment of institutional mechanisms for monitoring
and accountability to safeguard student mental well-being.
36. The above guidelines shall apply to all educational institutions across
India, including public and private schools, colleges, universities,
training centres, coaching institutes, residential academies, and
hostels, irrespective of their affiliation. We may clarify that these
guidelines are not in supersession but in parallel to the ongoing work
of the National Task Force on Mental Health Concerns of Students
and are being issued to provide an interim protective architecture in
the interregnum. We believe that these guidelines shall be read as
complementary to the ongoing work of the National Task Force and
would inform and assist the National Task Force in the development
of a more comprehensive and inclusive framework.

(iv) Directions:-
37. All States and Union Territories shall, as far as practicable, notify
rules within two months from the date of this judgment mandating
registration, student protection norms, and grievance redressal
mechanisms for all private coaching centres. These rules shall require
compliance with the mental health safeguards prescribed herein.
38. A district-level monitoring committee shall be constituted in each
district under the chairpersonship of the District Magistrate or
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Collector. The committee may include representatives from the
departments of education, health, and Child protection, civil society
and shall oversee implementation, conduct inspections, and receive
complaints.
39. Having regard to the serious and continuing nature of the concerns
addressed herein, we direct the Union of India to file a compliance
affidavit before this Court within a period of 90 days from the date of
this judgment. The affidavit shall detail the steps taken to implement
these guidelines, the coordination mechanisms established with
State Governments, the status of regulatory rulemaking with respect
to coaching centres, and the monitoring systems put in place. The
affidavit shall also indicate the expected timeline for the completion
of the report and recommendations of the National Task Force on
Mental Health Concerns of Students.
40. Let a copy of this judgment be circulated to the Ministry of Education,
Ministry of Health and Family Welfare, Ministry of Law and Justice,
University Grants Commission, National Council of Educational
Research and Training, Central Board of Secondary Education, All
India Council for Technical Education, and the Chief Secretaries
of all States and Union Territories for immediate compliance and
necessary action.
41. The present appeal is disposed of, accordingly.
42. In view of the disposal of the above appeal, no further orders are
required to be passed on the application(s) seeking impleadment
as well as application (I.A. No. 63866/2025) seeking direction to
produce chemical/medical reports, hence, the same stands disposed
of as infructuous.
43. Pending application(s), if any, shall also stand disposed of accordingly.
44. List again on 27th October, 2025, for receiving the compliance report.

Result of the case: Appeal disposed of.

†
Headnotes prepared by: Divya Pandey