INTRODUCTION
In CBI v. Sridhar & 9 Others [SC No. 470 of 2020], decided on 6 April 2026 by the
First Additional District and Sessions Court, Madurai, the Court delivered a
powerful Judgment addressing the issue of custodial violence and abuse of police
authority. The case, arising out of the tragic deaths of Jeyaraj and his son Bennix,
underscores the constitutional commitment to protection of life and dignity under
Article 21. The Court, after a detailed evaluation of evidence, convicted multiple
police officials and imposed severe sentences, including capital punishment in
appropriate cases.
BRIEF FACTS
The case stemmed from an incident in June 2020, when Jeyaraj and Bennix were
taken into custody by local police in connection with alleged violation of COVID-19
restrictions. What began as a routine police action soon escalated into a grave
instance of custodial brutality. The evidence on record demonstrated that both
individuals were illegally detained and subjected to prolonged and inhuman physical
assault within the police station premises. Despite their deteriorating condition, no
timely or adequate medical intervention was provided and they were subsequently
remanded to judicial custody, where their condition worsened, ultimately leading to
their deaths.
ISSUES OF LAW
The Court was required to determine whether the acts of the accused police officials
constituted offences of murder, wrongful confinement, destruction of evidence and
criminal conspiracy and whether the prosecution had established these charges
beyond reasonable doubt through medical, documentary and circumstantial
evidence.
ANALYSIS OF THE JUDGMENT
The Court’s reasoning is rooted in a meticulous appreciation of evidence, both direct
and circumstantial. It relied heavily on medical reports, which revealed multiple
external injuries consistent with repeated blunt force trauma, establishing that the
deaths were not accidental but the direct consequence of sustained assault. The
Court also considered jail records and witness testimonies, including statements of
inmates, which corroborated the account of custodial torture. These materials
collectively established a clear and unbroken chain linking the Accused officials to
the acts of violence.
Equally significant was the Court’s examination of the conduct of the Accused after
the incident. It found that attempts had been made to fabricate a false narrative by
registering cases against the victims and manipulating official records to create a
semblance of legality. The destruction of material evidence, including cleaning of the
crime scene and disposal of incriminating articles, further strengthened the inference
of guilt. The Court also noted inconsistencies and procedural lapses in medical
examination, which indicated an attempt to downplay the severity of injuries.
In evaluating these circumstances, the Court held that the actions of the Accused
were not isolated acts of excess but constituted a coordinated and deliberate abuse
of authority. The victims were unarmed civilians and the force used against them
was grossly disproportionate and unjustifiable. The Court emphasised that custodial
violence represents one of the most serious violations of human rights, as it involves
abuse of power by those entrusted with enforcing the law.
The Judgment further reflects on the broader implications of such conduct, observing
that any tolerance of custodial brutality would erode public confidence in the justice
system. The Court therefore rejected any leniency and proceeded to assess the
case within the framework of the “rarest of rare” doctrine, ultimately concluding that
the brutality, abuse of position and subsequent attempts to cover up the offence
justified the imposition of the highest punishment.
CONCLUSION
The Court ultimately convicted the accused police officials for offences including
murder, wrongful confinement, destruction of evidence and criminal conspiracy.
Taking into account the brutality of the custodial assault, the abuse of official position
and the subsequent attempts to fabricate records and destroy evidence, the Court
held the case to fall within the category of the “rarest of rare”. Accordingly, the
Principal Accused were awarded the death penalty under Section 302 of the Indian
Penal Code, while other Accused persons were sentenced to varying terms of
imprisonment for allied offences, including wrongful confinement and destruction of
evidence. The Court also imposed substantial fines, directing that the amounts be
paid as compensation to the family of the deceased.
By imposing the harshest punishment known to law, the Court sent a strong and
unequivocal message that custodial torture resulting in death will not be tolerated
and will attract the highest degree of criminal liability, particularly when committed by
those entrusted with maintaining law and order.
SUSHILA RAM VARMA
Advocate & Chief Consultant
The Indian Lawyer & Allied Services
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