‘Deliberate Cover-Up’: SC Orders CBI Probe Into 2024 Chhattisgarh Custodial Death

The Supreme Court recently transferred to the Central Bureau of Investigation (CBI) the investigation into the alleged custodial death of a man arrested for possessing illicit liquor in Chhattisgarh in 2024, finding that State authorities had “conveniently and deliberately” attempted to cover up the circumstances surrounding his death.

A Bench of Justices Vikram Nath and Sandeep Mehta also directed the Chhattisgarh Government to pay interim compensation of Rs 25 lakh to the deceased man's wife and children. The Bench directed the CBI chief to entrust the probe to a senior officer for an expeditious investigation.

Why did the Supreme Court order a CBI probe into the custodial death?

Court found that the State authorities had failed to take appropriate action despite a judicial inquiry finding that the deceased had suffered custodial violence and that his death resulted from head injuries.

“The stance blissful ignorance taken by the senior officers of the State of Chhattisgarh, including the Principal Secretary (Home); the Director General of Police and the Director General (Prisons), is sacrilegious and reflects a disturbing disregard of the statutory procedure governing custodial deaths,” the Bench said.

Court also directed the CBI to examine the conduct of the concerned State officials in failing to act on the judicial inquiry report and make the findings part of its investigation.

How did Shravan Suryavanshi die in custody?

Shravan Suryavanshi alias Sarvan Tamre was arrested in connection with an FIR registered on January 18, 2024, at Police Station Seepat in Bilaspur under Section 34(2) of the Chhattisgarh Excise Act.

He had allegedly been found possessing three bottles, each containing two litres of raw Mahua liquor, making a total of six litres valued at Rs 1,200.

Shravan was lodged at Central Jail, Bilaspur. After his health deteriorated, he was referred to CIMS Hospital, Bilaspur, on January 21, 2024. He died while undergoing treatment at around 6 am the following day.

The post-mortem examination recorded the cause of death as cardio-respiratory arrest due to complications arising from a head injury caused by a hard and blunt object. It also recorded that the injuries were antemortem, meaning they were suffered before death.

A judicial inquiry report submitted on July 22, 2024, similarly found that his death appeared to have been caused by complications arising from the head injuries.

What did the Chhattisgarh authorities tell the Supreme Court?

The case reached the Supreme Court after the deceased's wife, Lahra Bai Tamare, and others challenged an October 3, 2024 judgment of the Chhattisgarh High Court.

The high court had directed payment of only Rs 1 lakh compensation against their demand for Rs 50 lakh. Although it recorded that Shravan had been subjected to custodial violence and died as a result, it did not issue any direction for action against the police officers.

While hearing the challenge, the Supreme Court sought the virtual presence of the Director General of Police, Director General (Prisons) and Principal Secretary (Home) of Chhattisgarh.

The DGP told the Court that no criminal case had been registered because the police had not received the inquiry report under Section 176 of the CrPC [corresponding to Section 196 of the Bharatiya Nagarik Suraksha Sanhita (BNSS)]. According to the DGP, there was therefore no occasion to register a case to investigate Shravan's custodial death.

The Director General (Prisons), meanwhile, gave an explanation for the failure to forward the judicial inquiry report to the police for necessary follow-up action. The Principal Secretary (Home) also adopted a similar approach.

The Supreme Court rejected these explanations.

“The explanation offered that neither any police action nor any disciplinary action was taken against the persons responsible because the judicial inquiry report had not been served upon the police officials is a cover-up story and an attempt to pull the wool over the Court’s eyes,” the Bench said.

It further held that the DGP's submission that there was no occasion to register a criminal case was “patently false and wholly reprehensible".

Why did the Supreme Court find an attempt to mislead the inquiry?

Court also examined the medical records and found a significant discrepancy between the medical report prepared at the jail and the subsequent post-mortem report.

The jail medical report had recorded the cause of death as cardiopulmonary arrest with aspiration pneumonitis, with alcoholic withdrawal and delirium tremens as the diagnosis.

However, there was no reference in that report to any head injury or other injuries later detected during the post-mortem examination.

The post-mortem, in contrast, recorded multiple external injuries and concluded that the cause of death was cardio-respiratory arrest due to a head injury and its complications caused by a hard and blunt object.

“There is no reference whatsoever in the said medical report to the head injury or any of the other injuries subsequently noticed in the post-mortem report,” the Bench said.

Court held that these facts clearly warranted immediate registration of an FIR and a thorough investigation into the circumstances leading to Shravan's death, which the State authorities had “conveniently and deliberately” tried to cover up.

It also noted that the post-mortem report had not been placed before the High Court and that the relevant material was brought on record only after directions from the Supreme Court. This, it said, further highlighted the “dilatory approach” of the State authorities.

Supreme Court directs CBI to probe, Chhattisgarh to pay Rs 25 lakh

Court directed the DGP to ensure that the complete case records were sent to the CBI Director through a special messenger within one week.

It also directed the CBI chief to entrust the investigation to a senior officer and ordered the Investigating Officer's report to be placed before the Court on the next date of hearing.

“As an interim measure, we direct that compensation to the tune of Rs 25,00,000 shall be paid by the State of Chhattisgarh to the petitioners herein,” the Bench said, adding that the final compensation would be determined while deciding the petition.

The matter has been posted for October 13, 2026.

Case Title: Lahra Bai Tamare & Ors Vs State of Chhattisgarh And Ors

Bench: Justices Vikram Nath and Sandeep Mehta

Date of Judgment: August 12, 2026