Supreme Court Upholds High Court's Direction for CBI Probe into Controversial Death and Conflicting Wills

A bench of Justice Dipankar Datta and Justice Prashant Kumar Mishra heard appeals challenging a Karnataka High Court order that had directed the Central Bureau of Investigation (CBI) to conduct further investigation into the mysterious death of K. Raghunath and associated offences registered as Crime Nos. 89 of 2020, 148 of 2020 and 7 of 2021. The appeals were filed by Ramachandraiah and others and by D.A. Srinivas and others against the High Court's writ dated 03.09.2022.

The Supreme Court affirmed the High Court's order and dismissed the appeals, holding that constitutional courts possessed the extraordinary power to direct a CBI investigation in appropriate cases. The Court noted that such power must be exercised "sparingly and in exceptional circumstances" but was necessary when facts demanded to "provide credibility and instil confidence" and to do "complete justice". The Court, in its reasoning, observed: "It has been settled in catena of decisions that the High Court or the Supreme Court being Constitutional Court is vested with extra-ordinary power to direct CBI investigation depending upon the facts and circumstances of the case. ... In 'Vinay Tyagi v. Irshad Ali' this Court has held that the power to direct for CBI investigation is to be exercised sparingly and in exceptional circumstances, but, when the facts so demand, it is extremely necessary to exercise the said power to provide credibility and instil confidence in order to do complete justice and for enforcing the fundamental rights." The Court further recorded the Magistrate's finding that the SIT investigation was "unsatisfactory, shoddy and callous" and agreed that a fresh, impartial probe by CBI was warranted on the record before it.

Background

The dispute arose after the death of K. Raghunath in May 2019. The deceased, a real estate owner closely associated with a late Member of Parliament (referred to as DKA), was found hanging at a guest house; initially the HAL Police recorded an unnatural death report and closed the matter as suicide based on a statement of the deceased's son. Subsequently the deceased's wife lodged a private complaint alleging murder and forgery connected with competing wills — a registered Will dated 28.01.2016 in favour of the wife and another Will dated 20.04.2018, allegedly fabricated, favouring other family members. Following a magistrate's inquiry, FIRs were registered (Crime Nos. 89/2020, 148/2020 and 7/2021) and a Special Investigation Team (SIT) submitted a 'B' report. The Magistrate rejected the 'B' report and directed further investigation; the High Court allowed the writ petition filed by the deceased's wife in part and issued a writ of mandamus to the CBI to investigate further.

The appellants contended that the Magistrate had no jurisdiction to order further investigation for offences triable exclusively by the Sessions Court and that the order transferring investigation to CBI was illegal; they also pointed out that a challenge to registration of FIR had been withdrawn earlier in the High Court. The respondents relied on material said to show fabrication and irregularities in earlier investigations, including a Truth Lab report and allegations of forged stamp papers. The Supreme Court held that the appellants' earlier withdrawal of the challenge to FIR registration rendered that issue non-justiciable in the present proceedings and reiterated settled precedents (including Vinay Tyagi, Pooja Pal and related authorities) that constitutional courts may, in exceptional cases, direct reinvestigation or transfer investigation to a specialised agency. Applying those principles to the record, the Court found that a fair and credible probe by the CBI was required.

Final directions issued by the Court included an order that the CBI complete its investigation within eight months, that the State of Karnataka provide all assistance, and that the concerned police hand over all papers to the CBI within 15 days; if the CBI filed a chargesheet, it was to be submitted before the jurisdictional CBI Court in Karnataka. The appeals were dismissed.

Case Details: Case No.: 2025 INSC 556 Case Title: Ramachandraiah & Anr. v. M. Manjula & Ors.; D.A. Srinivas & Anr. v. M. Manjula & Ors. Appearances: For the Petitioner(s): Aman Lekhi, Senior Counsel For the Respondent(s): Mukul Rohatgi, Senior Counsel; Dushyant Dave, Senior Counsel