NHRC’s Role in Prevention of Custodial Death or Death During the Course of Police Action - by Rachna Mishra & Utkarsh Mishra
NHRC’s Role
in Prevention of Custodial Death or Death During the Course of Police Action
Author:
Rachna Mishra
Email: rachhuu25@gmail.com
Mob.: 9407048840
Co.Author:Utkarsh Mishra
Mob.: 8074618695
Introduction:
National Human Rights Commission and Custodial Deaths in Indian Criminal
Justice System
Custodial
Death can be defined as the death of a person in custody, either in Police or
Judicial custody. In former, the person is in physical custody of the police
and is kept in police station and in latter the person is under the concerned
magistrate and is kept in prison.[1]
The
Indian Criminal Justice System has been facing a chronic issue of custodial
death or death during the course of police action. As per the data provided by
NHRC, a total of 894 cases of Custodial Deaths have been reported.[2]
With a total of 204 recorded deaths between 1 January 2017 and 2 August, 2017,
UP leads the troll of death, followed by Punjab with 76 deaths and Bihar with
64 deaths.[3]
Though NHRC has been attempting to
curb this issue starting from its first guidelines regarding the same in the
year 1993, however there has not been any substantial decrease in the custodial
death matters. The present project deals with the development of guidelines
issued by NHRC through multiple case studies as well as a critical analysis of
the effective implementation of these guidelines.
National
Human Rights Commission
The National Human Rights Commission
(NHRC) was established in 1993 based on the provisions of the Protection of
Human Rights Act, 1993.[4]
The National Human Rights Commission of India was set up in conformity with
'Paris Principles'. The Commission is an autonomous institution both
functionally and financially with a wide mandate for better protection of Human
Rights. The Commission is deeply concerned with better protection of human
rights and continued its work on issues like terrorism and insurgency, torture,
custodial crimes, prison reforms, rights of disabled, health, rights of
mentally challenged, food security, education, rights of minorities, Scheduled
Castes and Scheduled Tribes and internally displaced persons, etc.
The NHRC does not have prosecutorial
powers, but it may recommend that the government initiate prosecution of
officials, or approach the Supreme Court or High Court to issue directions or
orders. It also has authority to review and recommend measures to effectively
implement human rights safeguards and to recommend that the government provide
immediate interim relief to victims in the form of monetary compensation.
The NHRC has issued guidelines
requiring that police report every case of custodial death to the commission
within 24 hours and that a magistrate should inquire into every case of death,
preferably within three months.[5] To
ensure fair and impartial investigation, police should register a First
Information Report (FIR) whenever a culpable act of homicide is alleged, and
the case must be investigated by a police station or agency other than the one
implicated. Further, the NHRC asks that post-mortems in custodial deaths should
be filmed and the autopsy report should be prepared as per the commission’s
model form.[6] Police
are also required to submit a second report to the NHRC in all these cases that
should include a post-mortem report and findings of a magisterial or
departmental inquiry into the death.
Difficulties
with NHRC
A 2011 report by the All India
Network of NGOs and Individuals working with the National and State
Human Rights Institutions (AiNNI) also raised concerns over the seeming lack of
independence of the NHRC. It noted that the NHRC was tightly controlled
financially by the government of India and reported to the Ministry of Home Affairs,
the same governmental department responsible for internal security, including
police and other law and order officials, therefore undermining its
independence.
The NHRC instituted a high-level
advisory committee and submitted a set of recommendations to the central
government in 2000 to amend the Protection of Human Rights Act to strengthen
the functioning of the commission. The act was amended in 2006, but significant
problems remain. It cannot independently make public its findings until the government
first places the report before parliament.
The amendments do not include lifting
the one-year “statute of limitations” on NHRC investigations, a time limit that
is unrealistic given the difficulty many victims have in obtaining counsel and
their limited awareness of their rights under the act.
The NHRC is still not authorized to
investigate complaints of human rights violations by the armed forces,
including the paramilitary Border Security Force and the Central Reserve Police
Force.[7]
The NHRC is also only a recommendatory/advisory devoid of a mechanism for
enforcing of its recommendations.
LITERATURE
REVIEW
The researcher has primarily referred
the official website of NHRC of India for referring to the cases investigated
by the commission and guidelines issued. The Guidelines of NHRC regarding the Procedure
to Be Followed in Cases of Death Caused in Police Station published in the
year 1993 and then revised in the year 2010 has been referred to understand the
situation of custodial deaths and actions to be taken by the police.
The researcher has also referred the
guidelines issued by NHRC on regarding conducting Magisterial Enquiry in
Cases of Death in Custody Or in The Course Of Police Action, published in
the year 1993. These reports also provided detailed procedure to be followed by
the Police in making videography report of the post-mortem of the death caused
in custody.
Multiple news reports have also been
referred to collect information regarding recent cases of custodial death which
are reported and investigated by the Commission. A news report by The
Times of India, provided for the suo motu cognizance taken by
NHRC based on media reports about the death of a man in police custody in
Pilkhua in Uttar Pradesh.[8]
STATEMENT
OF PROBLEM
The guidelines issued by the
Commission, to control the increasing cases of custodial deaths in India have
not been implemented effectively.
HYPOTHESIS
NHRC has not been able to limit the
cases of custodial deaths in India.
RESEARCH
QUESTIONS
1. What is the current state of India
regarding the cases of Custodial Deaths in India?
2. How NHRC deals with the cases of
Custodial Deaths or deaths during Police Actions?
3. Whether NHRC has been able to limit
the cases of deaths during custody of Police?
RESEARCH METHODOLOGY
The researcher has used
doctrinal mode of research method and main sources included are news reports
and internet resources.
OBJECTIVE OF THE STUDY
·
To
understand and analyse the reasons behind the increasing number of cases of
custodial deaths in India.
·
To
critically analyse the role played by NHRC to curb the issue of Custodial
Deaths in India.
·
To
evaluate the extend of implementation of guidelines issued by NHRC for limiting
the cases of custodial deaths.
·
To
find ways to impose liability upon police officials for their acts, to resolve
the issue of custodial death.
TENTATIVE CHAPTERISATION
CHAPTER 1: Introduction: National Human
Rights Commission and Custodial Deaths in Indian Criminal Justice System
CHAPTER 2: Prohibition and Causes of Custodial
Deaths: National and International Obligations of India
CHAPTER 3: Custodial Deaths: Case Studies and
Measures undertaken by NHRC
CHAPTER 4: Suggestions and Conclusion
·
CHAPTER 2: Prohibition and Causes of
Custodial Deaths: National and International Perspective
India’s
International Obligation
India has ratified the International
Covenant on Civil and Political Rights and signed the Convention against
Torture and Other Cruel, Inhuman or Degrading Treatment, both of which prohibit
torture and cruel, inhuman, and degrading treatment or punishment. They also
provide for the authorities to prosecute the officials responsible. These
commitments are reflected in Indian central and state laws that condemn
torture, and provide some procedural safeguards against it.
Domestic
Safeguards` for Custodial Deaths
The Indian Penal Code has several
provisions prohibiting custodial violence. For instance, under section 330
of the code, voluntarily causing hurt for the purpose of extorting a confession
or to compel restoration of property carries a punishment of up to seven years
in prison and a fine.
This also applies to police officials
who use torture to obtain a confession or information about stolen property. If
the harm inflicted is grievous, the punishment can extend up to 10 years in
prison. Public servants disobeying the law, with intent to cause injury to any
person, can go to prison for one year.
In 1985, the Law Commission of India
had recommended that the Indian Evidence Act, 1872, be amended to stipulate
that if a person suffers any bodily injury while in police custody, the courts
may presume that the injury was caused by the police officer who had the custody
of that person.[9] the
Supreme Court’s judgment in D.K. Basu lays down certain
guidelines to establish mandatory procedures for police detention, including
interrogation.[10]
Under the Code of Criminal Procedure,
in addition to police investigation, an inquiry by a judicial magistrate is
mandatory in cases of death, enforced disappearance, or alleged rape in police
custody.[11]
However, the NHRC has interpreted the law to mean that an inquiry by a judicial
magistrate is not in fact mandatory in all such cases. In April 2010, the NHRC
sent a notification to all states saying a judicial inquiry is mandatory only
in those cases of custodial deaths “where there is reasonable suspicion of foul
play or well-founded allegation of commission of an offense. All other cases of
custodial death where the death is natural or caused by disease may be enquired
into by an executive magistrate.”[12]
Though there are multiple safeguards
under national as well international level, however, there are a huge number of
reasons behind the increasing number of custodial deaths in India. Some of them
are as follows:
1. No accountability of police:
In the wake of the government’s failure to implement
recommendations from the National Police Commission, including a wide range of
measures to modernize the police, guidelines for reducing police harassment of
the public, and limits on the use of “third degree” interrogation methods[13],
the Supreme Court in a landmark decision, Prakash Singh v. Union of India[14],
issued six binding directives to the central and state governments to
kick-start police reforms.
The Supreme Court directives were aimed at improving the
functional autonomy of the police through security of tenure, streamlining
appointment and transfer processes, insulating the police from government’s
interference and influence, and enhancing police accountability.[15]
The Supreme Court in 2008 it set up a three-member monitoring committee under
former Supreme Court justice K.T. Thomas with a two-year mandate to examine
compliance by states and report back periodically. The committee submitted its
report on August 2010, observing a huge ignorance to the directives of the
court by the States.[16]
2. In some States, after a case of
custodial death, the enquiry is done by the executive magistrate not a judicial
magistrate (an executive body).
3. Internal departmental enquiries are
done, which are of no use and try to portray the death to be an accident or a
natural death.
4. Govt. doctors favour the police
Autopsy and forensic reports frequently support the police version of events
even where there is no apparent basis.
5. The national and state human rights
commissions have largely failed in their oversight role in cases of custodial
killings. The National Human Rights Commission is empowered to summon witnesses,
order production of evidence, and recommend that the government initiate
prosecution of officials. However, in practice its recommendations have mostly
been limited to calling on the government to provide compensation or other
immediate interim relief. Between April 2012 and June 2015, of the 432 cases of
deaths in police custody reported to the NHRC, the commission recommended
monetary relief totalling about 22,910,000 rupees but recommended disciplinary
action in only three cases and prosecution in none.
6. Lack of training and resources for
scientific methods of forensic investigation contribute to the use of torture
during interrogations. Forensic laboratories are often understaffed and have a
significant backlog of cases.
CHAPTER 3: Custodial Deaths: Case Studies and Measures
undertaken by NHRC
Efforts of
NHRC to Curb Custodial Deaths
The Commission came into effect on 28th
September, 1993 and in the view of the rising number of incidents of custodial
deaths and custodial rapes, it issued its first guideline regarding the
reporting of custodial deaths within 24 hours by the Superintendents of Police
of every district. Failure to report promptly would give rise to presumption
that there was an attempt to suppress the incident.
The Commission has dealt with
multiple cases and has given ample of guidelines to limit the matters of
custodial deaths.
In 1993-94, the Commission took suo
motu cognizance on the death of Madan Lal, 22 years of age, in
police custody. Upon perusing the reports received from the Government of the
National Capital Territory of Delhi, the Commission decided to have an
investigation undertaken in terms of Section 14(1) of the Protection of Human
Rights Act, 1993. It accordingly appointed Shri R.C. Chopra, a member of the
Higher Judicial Service to investigate the matter.
Shri Chopra submitted a report on 11
March 1994 concluding that Shri Madan Lal had died as a result of a physical
assault on his person, while he was in custody within a police station. The
Commission gave recommendations to the Govt. of NCT Delhi and the same were
incorporated by it.
Later, on Aug. 10, 1995, the
Commission, after Scrutinising the reports in respect of all custodial deaths,
was of the view that the post-mortem in many cases has not been done properly.
Usually the reports are drawn up casually and do not at all help in the forming
of an opinion as to the cause of death. The Commission has formed an impression
that a systematic attempt is being made to suppress the truth and the report is
merely the police version of the incident. Therefore, the Commission
recommended that all post-mortem examinations done in respect of deaths in
police custody and in jails should be video-filmed and cassettes be sent
to the Commission along with the post-mortem report.
In addition to this, in the year
1995-96, the Commission recommended State Governments to recover compensation
amounts from the offending police officials. The Commission took the view
that if this were done, the exchequer would not be burdened with the liability
of paying compensation resulting from the "unauthorized, unlawful and
illegal acts of public servants."
Custodial
Death of Shri Bundoo in Uttar Pradesh[18]
The Senior Superintendent of Police,
Moradabad on 14 October, 1995 reported the death of one Bundoo while in
custody. In their report, the Government stated that on 12 October 1995 a case
was registered at Police Station Chandpur, Bijnore District against four named
persons. After being handcuffed, the accused were taken to the site for
identification in course of investigation. Suddenly, Bundoo jumped out of the
vehicle and came to fall in front of a moving bus. He received serious injuries
which ultimately led to his death at Moradabad District Hospital.
The Commission recommended that an
enquiry be undertaken immediately and the concerned police officers and the
constables, if found guilty of negligence, be adequately punished. The State
Government vide letter dated 15.9.98 submitted that enquiry is conducted in the
matter. However, no police officer was found guilty and this report was
accepted by Chief Judicial Magistrate, Moradabad.
Custodial
death of Atal Bihari Mishra - Uttar Pradesh[19]
A reference to the case was made in
the annual report of the Commission for the year 1996-97. It was mentioned that
a number of police personnel were charge-sheeted in this case, consequent to
intervention by the Commission. As there was prima facie material to hold that
Atal Bihari Mishra died as a result of police violence, the Commission issued
notice to the Chief Secretary, Government of Uttar Pradesh, to show cause why a
reasonable interim-compensation should not be awarded to the members of the
family of the deceased.
By a communication dated 28 December
1997, the State Government stated that, as a case in connection with the murder
of Atal Bihari Mishra was pending in the Court of Chief Judicial Magistrate,
Balia against 21 police officials, compliance of the directions/recommendations
of the Commission could only be possible after the police officials/accused
persons were found guilty of the charges.
However, the Commission recommended
that the award of "Immediate Interim Relief" envisaged in sub-section
(3) of Section 18 of the Protection of Human Rights Act 1993 will loose its
essence if the establishment of criminal liability is waited for. Therefore, it
was recommended to the UP government to provide interim relief to the victim’s
family.
On January 3, 2001, the Commission
issued another guideline to curb the delay in sending the post-mortem
report along with videography and ultimately causing delay in awarding interim
relief to the victim’s kin. The Commission said that the post-mortem report
with all the relevant documents to be submitted before it within two months
of the incident.
Illegal
Detention, Torture and Death of Shah Mohammed in Police Custody (M.P.)[20]
he Commission initiated proceedings
in this case upon receipt of a wireless message from the Superintendent of
Police, Durg which indicated that the custodial death had occurred of a certain
Shah Mohammed, a resident of Bhilai in district Durg of Madhya Pradesh.
In response to a notice from the
Commission, the Government of Madhya Pradesh transmitted to the Commission
copies of the magisterial inquiry report, the post-mortem report, the inquest
panchnama and viscera examination report. However, the post mortem report did
not match with the magisterial enquiry report.
After investigation the Commission
concluded that Shah Mohammed was picked up by the police in the evening of 16
July 1996, kept in illegal detention in the police lock-up by the police of
Bhatti, Bhilai until the afternoon of 18 July 1996 and brutally tortured during
the period of his illegal detention. It was this that led to his death at the
police station in the afternoon of 18 July 1996, before he was removed to the
hospital.
Therefore, the Commission recommended
to Register a case of custodial death against the Officer-in-charge of the
Police Station and Initiate appropriate disciplinary proceedings against the
two Doctors who had not conducted the post-mortem examination thoroughly and
who had failed to prepare a comprehensive post-mortem examination report.
Death of
Dhirender Singh in Jail: Uttar Pradesh[21]
The Commission, on receiving
information of the custodial death of a prisoner named Dhirender Singh in the
District Jail, Jaunpur, called for a detailed report from the Government of
Uttar Pradesh. The report that was received stated that certain anti-social
elements' had gone to the main gate of the District Jail on that date and had
asked for an under-trial prisoner, Jaya Prakash Singh, on the pretext that they
had to hand-over a letter to him. Jaya Prakash Singh went to the main gate,
where the deceased was also present at that time. The 'anti-social elements'
fired at Jaya Prakash Singh, but he escaped. However, a stray bullet hit the
deceased in his stomach.
He was rushed to the hospital where
he was declared dead. A detailed magisterial inquiry that was instituted to
look into the matter arrived at the conclusion that there was negligence on the
part of the jail authorities and that this had resulted in the death of
Dhirender Singh.
The Commission by its order awarded a
sum of Rs. 75,000/- as immediate interim relief to the next of kin of the
deceased. As the State Government complied with the direction of the
Commission, the case was closed.
Death of
Devu Sattababu in Puducherry Police Custody[22]
The Commission received a complaint
from Devu Chandra Kala alleging that her husband Devu Sattababu was taken away
by the police on 10 November 2011 and he died on 11 November 2011 while in
police custody. Moreover, the police did not file any FIR as to the death of
her husband. She thus prayed for action against the police officer on duty as
well as compensation for violation of her rights.
On consideration of the report, from
the Deputy Inspector General of Police, Puducherry, the Commission on 28 April
2015 observed that the report itself admits that the death had occurred while
in police custody and due to negligence of their officers, hence the next of
kin of the deceased must be compensated.
Hyderabad
Encounters and HNRC’s Cognisance[23]
In the light of media reports that
the four people accused of the rape and murder of the veterinarian doctor in
Hyderabad have been killed in a police encounter, the NHRC has decided to take suo
motu cognisance of the same. The Commission has taken taken notes of the
fats that have emerged and passed orders for a spot inquiry by its
investigation team, headed by the Director General of the Investigating
Division.
The Commission has also sought report
from all the State governments, police heads as well as from the Union Ministry
of Women and Child Development, after having taken cognisance of the increasing
number of cases of rape and sexual assault on women across the country.
Though multiple steps have been taken
by the Commission to curb the increasing number of cases of custodial deaths,
it has not been able to limit the cases. Recently, Minister of state for home G
Kishan Reddy[24]
informed the Lok Sabha that NHRC has registered 427 cases relating to alleged
deaths of accused in police custody and 5,049 cases pertaining to deaths in
judicial custody.
The cases of deaths in police custody
registered by NH HRC in
2018-19 were 136 and of those in judicial custody, 1,797. The corresponding
number of cases involving alleged deaths in police custody and judicial custody
in 2017-18 were 146 and 1,636 respectively and in 2016-17, 145 and 1,616
respectively.[25]
Therefore, there has been a considerable increase in the number of cases of
custodial death in India.
CHAPTER 4: Suggestions and Conclusion
Suggestions
·
As
per the provisions, the appointment of the Chairman and other members of the
Commission is under the hands of the Prime Minister Speaker, Home Secretary,
Deputy Chairman, leader of opposition in Lok Sabha and Rajya Sabha. Therefore,
the appointing committee is not free from political compulsion. The Protection
of Human Rights Act, 1993 should be amended to provide provision for
appointment like the collegiums of the Judges of the Supreme Court and the
Chief Justice of the High Courts.
·
One
member from the two members appointed from amongst persons having knowledge of,
or practical experience in, matters relating to human rights, should be a
person from any leading NGO who is primarily working on protection of Human
Rights.
·
The
Act should be amended so as to make the recommendations made by the Commission
binding and punishable in case of derogation.
·
It
lacks transparency and, in its observation, it is considered to be another
governmental agency or controlled organisation. This should be removed by
limiting the political involvement as well as allocation of funds by the
Parliament should be changed to extracting funds from Budget directly.
·
Provisions
should be made, regarding the accountability of Police Officials and their
illegal acts, prescribing adequate punishments.
·
Adequate
resources and infrastructure should be provided to police officials to decrease
the work load and discourage them to assort to forceful means to extract
information from persons put in custody.
Conclusion
The NHRC has attempted to limit the
cases of custodial deaths, however due to multiple constraints, it has not been
able to do the same in an effective manner. Implementing the suggestions provided
above can help the Commission in decreasing the increasing number of cases of
custodial deaths in India.
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Judicial Custody And Police Custody, LiveLaw.in (Sept. 4, 2019);
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[2]Rishiraj Bhagawati, Almost 900
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[3]Id.
[4] Protection of Human Rights Act,
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43 of 2006,
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[5] National Human Rights
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[6] Letter from National Human
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[7] V. Venkatesan, “A Commission in
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[9] Law Commission of India, 113th Report
on Injuries in Police Custody, July 29, 1985,
http://lawcommissionofindia.nic.in/101-169/report113.pdf
[10] D.K. Basu v. State of West
Bengal, p. 14-15.
[11] Code of Criminal Procedure
(CrPC), section 176.
[12] Guidelines/Clarification issued
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[13] Bureau of Research and
Development, National Police Commission Reports, http://www.bprd.gov.in/index1.asp?linkid=281.
[14] Prakash Singh v. Union of India,
Supreme Court of India, 8 SCC 1, 2006,
[15] Commonwealth Human Rights
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[16] Final Report of Justice K.T.
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[17] National Human Rights
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[18] Supra note 17.
[19] Supra note 17.
[20] Case No. 3855/96-97/NHRC.
[21] See Case No.
21808/24/99-2000/CD), National Human Rights Commission, Annual Report 2002-03.
[22] (Case No.56/32/4/2011-PCD,
National Human Rights Commission, Annual Report 2015-16.
[23] Hyderabad Encounter : National
Human Rights Commission Takes Suo Moto Cognizance; Orders Spot Inquiry
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[24]http://timesofindia.indiatimes.com/articleshow/70250201.cms?utm_source=contentofinterest&utm_medium=text&utm_campaign=cppst.
[25] Id.