Supreme Court Orders CBI Probe Into Coaching-Hostel Death and Issues Nationwide Student Mental Health Safeguards

A bench of Justices Vikram Nath and Sandeep Mehta on July 25, 2025 heard an appeal against an order of the Andhra Pradesh High Court which had refused to transfer the investigation into the death of a 17‑year‑old student at a coaching‑institute hostel to the Central Bureau of Investigation (CBI). The appeal arose from competing FIRs and writ petitions filed after the student, who was studying at an Aakash Byju’s centre and staying in a hostel in Visakhapatnam, suffered fatal injuries on July 14–16, 2023.

The Court quashed the High Court order and directed immediate transfer of the investigation to the CBI. It recorded a string of procedural and evidentiary lapses by local authorities — inconsistent CCTV footage, the failure to obtain contemporaneous statements though the deceased was reported to have been responsive, non‑production or destruction of viscera and chemical analysis records, overlapping forensic and post‑mortem roles of the same medical officer, and material discrepancies between hospital records and an AIIMS medical board assessment. The Court, in its reasoning, observed: “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.”

Background The appellant, Sukdeb Saha, challenged an Andhra Pradesh High Court order dated February 14, 2024 which declined to transfer the probe into FIR No. 148 of 2023 (registered after the death of his daughter) to the CBI. The deceased had been undergoing NEET coaching at a Visakhapatnam centre and was lodged at Sadhana Hostel on the institute’s recommendation. After the incident she was treated at Venkataramana Hospital and later shifted to Care Hospital, where she died on July 16, 2023. The appellant had earlier approached the High Court under Article 226 seeking preservation of CCTV and forensic evidence; an Advocate Commissioner had been appointed and DNA testing and AIIMS referral directions were issued at different stages. The appellant alleged perfunctory local investigation, concealment or non‑production of chemical/forensic reports, contradictory CCTV imagery (different clothing in two clips), failure to record the injured student’s statement, and premature destruction of viscera by the regional FSL. The Andhra Pradesh police had altered charges and examined numerous witnesses, while respondents (institute, hostel and hospitals) denied negligence and asserted cooperation.

Relying on precedents that transfer to CBI was an “extraordinary” remedy to be exercised sparingly, the Court found that the cumulative procedural failures, evidentiary inconsistencies and apparent compromises of forensic independence created an exceptional situation warranting central investigation. The Court observed the broader social context of rising student suicides — referring to the phenomenon as a “suicide epidemic” in past jurisprudence — and emphasised protection of the right to mental health under Article 21.

The Court directed immediate handover of all case records, CCTV, forensic material and related documents to the Director, CBI, and required the CBI to register an RC, investigate under supervision and file a report under the relevant criminal procedure provision within four months. The Court clarified that its observations would not prejudice trial or defence.

In addition, treating the matter as raising systemic issues, the Court issued interim national guidelines for student mental health and suicide prevention to apply to educational institutions and coaching centres, mandated state rule‑making for registration and grievance redressal of private coaching centres within two months, required district monitoring committees, and directed the Union to file a compliance affidavit within 90 days. Copies of the judgment were ordered to be circulated to central and state education and health authorities.

Case Details: Case No.: Criminal Appeal @ SLP (Crl.) No(s). 6378 of 2024; 2025 INSC 893 Case Title: Sukdeb Saha v. The State of Andhra Pradesh & Ors. Appearances: For the Petitioner(s): [Advocates not specified in the judgment] For the Respondent(s): [Advocates not specified in the judgment]