Dharmasthala Mass Burial Case: Karnataka HC Stays Any Coercive Action Against Advocate

Advocate Manjunath N, representing complainant Sujatha Bhat whose daughter allegedly went missing in 2003, had been summoned by the Police after issuing a press release on the investigation

Update: 2025-09-10 12:32 GMT

The Karnataka High Court has kept in abeyance the police summons issued to Adv. Manjunath N in the Dharmasthala case

The Karnataka High Court has stayed the summons issued to an advocate linked to the Dharmasthala mass burial case, holding that no coercive steps should be taken against him until further hearing. 

Advocate Manjunath N approached the High Court to quash the FIR dated August 22, 2025, at Belthangady Police Station, registered under Sections 353(1)(B) and 353(2) of the Bharatiya Nyaya Sanhita. He also sought an interim stay on the operation of the same FIR during the pendency of proceedings.

Moreover, he sought directions restraining the police and authorities from taking coercive steps such as arrest, detention, interrogation, seizure of documents, or search of premises under the impugned FIR.

He argued that the FIR was misconceived, legally untenable, and violative of fundamental rights.

Advocate Manjunath N represents Sujatha Bhat in the Dharmasthala mass burial case, who had claimed that her daughter went missing in 2003 at Dharmasthala. The advocate was summoned through a police notice dated September 1, 2025, after he issued a press release referring to alleged burial sites and the progress of the investigation in the case.

Granting interim relief to the advocate, court directed that the summons be kept in abeyance, making clear that the issue touches upon the larger principle of lawyer-client privilege.

Referring to SLP No.9334/2025, the High Court noted that the Supreme Court had already cautioned against allowing agencies to directly summon advocates engaged in professional work. The apex court observed that such practices undermine the independence of the legal profession and could amount to a “direct threat to the administration of justice".
The High Court also took into account the suo motu proceedings initiated by the Chief Justice of India earlier this year, where multiple lawyer bodies pressed for guidelines to prevent harassment of advocates by enforcement agencies such as the ED, CBI, and the police. Reinforcing this position, a June 2025 circular of the Enforcement Directorate was cited, which bars the issuance of summons to lawyers in violation of Section 132 of the Bharatiya Sakshya Adhiniyam, 2023, a provision that safeguards professional communications between lawyers and their clients.
The Dharmasthala case itself has created a storm in Karnataka. Allegations surfaced of mass burials near the famed temple town, with claims of secret disposal of bodies spanning decades. An SIT was formed to probe the matter, and several individuals connected to the case, including complainant Sujatha Bhat and her counsel, came under police scrutiny.
By keeping the summons in abeyance, the High Court has effectively provided temporary relief to the lawyer.
The matter will now be heard on October 8, 2025.

Case Title: Manjunath N Vs. State of Karnataka & Anr

Order Date: September 4, 2025

Bench: Justice Sachin Shankar Magadum

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