Supreme Court Orders CBI Investigation in Mysterious Death Case: Ramachandraiah vs. M. Manjula (2025)

Introduction

Date of the Judgment: April 23, 2025
Citation: 2025 INSC 556
Judges: Dipankar Datta, J., Prashant Kumar Mishra, J.

Was the death of K. Raghunath a suicide or a murder? The Supreme Court of India recently addressed this question by ordering the Central Bureau of Investigation (CBI) to conduct a further investigation into the mysterious death of one K. Raghunath, amidst allegations of foul play and forged wills. This case, Ramachandraiah & Anr. vs. M. Manjula & Ors., delves into complex family disputes, property rights, and the integrity of investigative processes. The judgment was delivered by a bench comprising Justice Dipankar Datta and Justice Prashant Kumar Mishra.

Case Background

M. Manjula (Respondent No. 1) is the wife of the deceased, K. Raghunath, and Respondent No. 2 is their son. The deceased allegedly owned significant immovable properties in Bangalore and other locations. He was closely associated with D.K. Adikeshavalu (DKA), a Member of Parliament who passed away on April 24, 2013. Following DKA’s death, disputes arose over the properties held by K. Raghunath.

The children of DKA, particularly Respondent No. 12, allegedly pressured the deceased to transfer some of the properties, claiming that the income source for these properties originated from their father. However, the deceased resisted, asserting his absolute ownership based on his income from real estate. This led to significant conflict between the deceased and DKA’s children.

In 2016, an income tax raid occurred at DKA’s premises, which the respondents attributed to the deceased. The deceased had allegedly executed a registered Will on January 28, 2016, bequeathing all his properties to his wife, Respondent No. 1. On May 2, 2019, the deceased informed his family that he was going to meet with Respondent Nos. 12 and 14. He went missing for two days. On May 4, 2019, the family received a call from the deceased stating that his life was in danger.

Respondent No. 2 found his father hanging from a ceiling fan at a guest house in Whitefield, Bengaluru, on the same day. Initially, Respondent No. 2 did not suspect anyone and gave a statement to the police indicating that it appeared to be a suicide. Based on this statement, the police filed an unnatural death report (U.D.R.No.28 of 2019) and closed the case.

On February 15, 2020, Respondent No. 1 filed a complaint alleging that her husband had been murdered by Respondents 12 to 14 and others. The police refused to register the complaint, leading Respondent No. 1 to file a private complaint (P.C.R.No.51691 of 2020) under Section 200 of the Cr.P.C, alleging the murder of her husband by Respondents 10 to 14. The Magistrate ordered an inquiry on March 2, 2020, and an FIR was registered against Respondents 10 to 13 and the appellants in Crime No. 89 of 2020, for offences punishable under Sections 34, 120B, 467, 468, 421, 474, 302, 464, and 471 of the IPC.

Subsequently, two other crimes were registered: Crime No. 148 of 2020 under Sections 34, 120B, 468, 465, 471, and 420 of the Indian Penal Code, 1860, against the appellants and Respondent Nos. 12 and 13; and Crime No. 7 of 2021 under Sections 420, 255, 257, 259, 256, 258, and 260 of the Indian Penal Code, 1860, against unknown persons. These crimes were registered approximately ten months after the incident.

Timeline:

Course of Proceedings

Initially, the respondents approached the High Court in Writ Petition No. 4333 of 2021, seeking the constitution of a Special Investigation Team (SIT) due to the delayed investigation. The High Court directed the formation of a three-member SIT, which conducted an investigation and filed a ‘B’ report (closure report) before the concerned court in Crime No. 89 of 2020 and other related crimes.

The Magistrate, however, rejected the ‘B’ report on February 21, 2022, finding the SIT’s investigation to be unfair and lopsided. The Magistrate directed the Station House Officer of HAL Police Station to conduct further investigation and submit a report by April 22, 2022, noting that the SIT had failed to consider material aspects leading to the deceased’s death.

The respondents then challenged the Magistrate’s order, seeking a CBI investigation, given the SIT’s filing of a ‘B’ report. The High Court, in its impugned order, partly allowed the writ petition, issuing a writ of mandamus to the CBI to conduct further investigation. The High Court held that the Magistrate’s direction for further investigation by the HAL Police Station was without jurisdiction.

Following the High Court’s order, the CBI registered an FIR against the appellants and Respondent Nos. 12 to 14 on September 30, 2022. The appellants then appealed against the High Court’s order.

Legal Framework

Several legal provisions were central to the arguments and the court’s decision:

• Section 200 of the Cr.P.C (Code of Criminal Procedure): This section deals with the examination of a complainant by a Magistrate. It allows a Magistrate to take cognizance of an offense upon receiving a complaint.
• Section 190(1)(a) of the Cr.P.C: This section empowers a Magistrate to take cognizance of an offense upon receiving a complaint of facts which constitute such offense.
• Section 202 of the Cr.P.C: This section allows the Magistrate to postpone the issue of process and inquire into the case himself or direct an investigation to determine whether there is sufficient ground for proceeding.
• Section 202(2) of the Cr.P.C: This section specifies that if the offense complained of is triable exclusively by the Court of Session, the Magistrate shall call upon the complainant to produce all his witnesses and examine them on oath.
• Section 173(2) of the Cr.P.C: This requires the police officer to forward a report to the Magistrate on completion of the investigation.
• Section 173(8) of the Cr.P.C: This section provides for further investigation even after a report has been filed under Section 173(2).
• Section 174 of the Cr.P.C: This section deals with inquiries into cases of suicide or death under suspicious circumstances.
• Section 482 of the Cr.P.C: This section saves the inherent powers of the High Court to make orders necessary to give effect to any order under this Code, or to prevent abuse of the process of any Court or otherwise to secure the ends of justice.
• Sections 34, 120B, 467, 468, 421, 474, 302, 464, and 471 of the IPC (Indian Penal Code, 1860): These sections define various offenses, including common intention (Section 34), criminal conspiracy (Section 120B), forgery of valuable security (Section 467), forgery for the purpose of cheating (Section 468), fraudulent removal or concealment of property (Section 421), possessing forged material (Section 474), murder (Section 302), making a false document (Section 464), and using a forged document as genuine (Section 471).
• Sections 420, 255, 257, 259, 256, 258, and 260 of the IPC: These sections pertain to cheating (Section 420), counterfeiting government stamps (Section 255), fraudulently using a government stamp known to have been before used (Section 257), using a counterfeit government stamp (Section 259), possessing a counterfeit government stamp (Section 256), sale of counterfeit government stamp (Section 258), and using as genuine a government stamp known to be counterfeit (Section 260).

Arguments

Arguments by the Appellants:

• The appellants argued that the direction for a ‘further investigation’ by the CBI in Crime Nos. 89 & 148 of 2020 and Crime No. 7 of 2021 is illegal and unsustainable.
• They contended that the Magistrate lacked jurisdiction to take cognizance under Section 190(1)(a) Cr.P.C when proceedings under Section 174 Cr.P.C had been closed.
• It was argued that the private complaint was filed belatedly, over ten months after the incident, and after the respondents learned that the appellants were witnesses to the deceased’s last will, which bestowed limited benefits on Respondent Nos. 1 & 2.
• The appellants pointed out that Respondent No. 2, the informant in the UDR case, had initially stated that his father was in financial distress and committed suicide.
• They highlighted that the SIT, headed by a Deputy Commissioner of Police, had submitted a 639-page B-report, finding no material evidence to link the appellants to the allegations made by Respondent No. 1.
• The appellants argued that no direction for investigation could have been made by the Magistrate under section 202 of the Code as offence complained was triable exclusively by the Court of Session and Magistrate was obligated to make an enquiry and call upon the complainant to produce all her witnesses and examine them on oath as contained under section 202(2) of the Code.
• The appellants are elderly and impecunious farmers, with Appellant No. 1 being 89 years old.

Arguments by the Respondents:

• The respondents argued that the deceased, a confidant of former Member of Parliament DKA and a successful realtor, had lawfully acquired several movable and immovable properties to be succeeded by his wife and children.
• They claimed that the deceased, fearing for his life, had executed a Will on January 28, 2016, bequeathing all properties to his wife, Respondent No. 1.
• The respondents alleged that a fabricated Will dated April 20, 2018, was posthumously registered on December 31, 2019, bequeathing the deceased’s properties to Respondent No. 12 in conspiracy with Respondent No. 13 to extort the properties.
• They referred to a report from Truth Lab, which found the Will dated April 20, 2018, to be fabricated.
• The respondents pointed out discrepancies in the SIT report, as highlighted by the Magistrate and the High Court, arguing that the High Court rightly directed a fair and impartial investigation by the CBI.

Submissions Categorized by Main Submissions

Issues Framed by the Supreme Court

1. Whether the High Court was justified in directing an investigation by the CBI, given the facts and circumstances of the case.

Treatment of the Issue by the Court: “The following table demonstrates as to how the Court decided the issues”

Authorities

The court relied on several precedents to arrive at its decision:

• Vinay Tyagi vs. Irshad Ali, (2013) 5 SCC 762 (Supreme Court of India): This case established that the power to direct CBI investigation should be exercised sparingly and in exceptional circumstances to ensure justice and enforce fundamental rights.
• Pooja Pal vs. Union of India & Ors., (2016) 3 SCC 135 (Supreme Court of India): Reiterated that the power to direct CBI investigation must be exercised with great caution and only in exceptional situations to provide credibility and instill confidence in the investigation.
• Union of India & Anr. vs. W.N. Chadha, (1993) Supp (4) SCC 260 (Supreme Court of India): Held that a prospective accused has no right to be heard at the stage of FIR registration and has no say in the manner and method of investigation.
• Satishkumar Nyalchand Shah vs. State of Gujarat & Ors., (2020) 4 SCC 22 (Supreme Court of India): Reaffirmed the principle in W.N. Chadha that a proposed accused does not have any say at the stage of further investigation under Section 173(8) CrPC.
• Mandakini Diwan & Anr. vs. High Court of Chhattisgarh & Ors., (2024) SCC online SC 2448 (Supreme Court of India): Directed CBI investigation in a matter where the police had filed a closure report treating it as a case of suicide, emphasizing the need for a fair and independent investigation.

Authorities Considered by the Court and How

Judgment

The Supreme Court affirmed the order of the High Court, dismissing the appeals and directing the CBI to conduct the investigation within eight months. The State of Karnataka was directed to provide all possible assistance to the CBI for a fair investigation.

What weighed in the mind of the Court?

The Supreme Court’s decision to uphold the High Court’s order for a CBI investigation was influenced by several factors. The mysterious circumstances surrounding K. Raghunath’s death, coupled with allegations of forged wills and a perceived lack of thoroughness in the initial police investigation, weighed heavily on the Court’s decision. The Court emphasized the need for a fair, impartial, and complete investigation to uncover the truth and ensure justice.