Kerala High Court Directs SIT to Expedite Investigation in Crime No. 133/2024 of Koppam Police Station: Ensuring Fair Probe and Filing of Final Report at the Earliest

Court’s Decision:

The Kerala High Court, presided over by Justice Dr. Kauser Edappagath, disposed of the writ petition that sought the constitution of a Special Investigation Team (SIT) for the investigation of Crime No. 133/2024 registered at the Koppam Police Station, Palakkad. The court noted that an SIT had already been formed and was conducting the investigation. Therefore, it directed the SIT to complete the investigation promptly and submit the final report without unnecessary delay.

Facts:

1. The petitioners filed a writ petition under Article 226 of the Constitution, seeking judicial intervention to constitute a Special Investigation Team for an independent and impartial investigation into the death of Vinod.
2. The case was initially registered as Crime No. 133/2024 at the Koppam Police Station in Palakkad district.
3. The petitioners argued that there were substantial injuries on the deceased, as evidenced by:
   • Exhibit P1: A copy of the First Information Report (FIR) and the First Information Statement related to the crime.
   • Exhibit P2: The postmortem report issued by an Assistant Professor and Assistant Police Surgeon from the Government Medical College, Kozhikode, detailing the nature of the injuries on the deceased’s body.
   • Exhibit P3: A discharge summary from EMS Memorial Cooperative Hospital and Research Centre, which described the injuries sustained by the deceased and the medical treatment provided.

Issues:

1. Whether the court should order the constitution of a Special Investigation Team (SIT) for the case.
2. Whether the investigation being conducted by the existing SIT is satisfactory and sufficient to ensure justice.

Petitioner’s Arguments:

1. The petitioners claimed that the investigation carried out by the local police authorities lacked impartiality and thoroughness, necessitating judicial intervention to ensure an unbiased probe.
2. They argued that the serious injuries sustained by the deceased and the surrounding circumstances warranted a specialized investigative body capable of handling sensitive cases effectively.

Respondent’s Arguments:

1. The learned Public Prosecutor, M.P. Prasanth, informed the court that, pursuant to the petitioners’ concerns, a Special Investigation Team had already been constituted to investigate the case.
2. The prosecution asserted that the SIT was currently conducting the investigation, ensuring the investigation’s adequacy and addressing the petitioners’ apprehensions.

Analysis of the Law:

1. Scope of Article 226: The petition was filed as a writ of mandamus under Article 226, empowering the High Court to intervene in matters requiring public authorities to fulfill their duties.
2. Criminal Procedure Code (CrPC), 1973: The procedural law mandates that investigations must be carried out fairly and expeditiously to uphold the rule of law. The involvement of a Special Investigation Team is warranted when local authorities are perceived to lack objectivity or competence.
3. Judicial Intervention: Courts are often called upon to ensure investigations are carried out diligently, particularly in cases involving sensitive circumstances like unnatural deaths or allegations of negligence.

Precedent Analysis:

1. While no specific precedents were cited in the judgment, the court’s directive aligns with principles laid out in landmark cases involving the constitution of SITs for unbiased investigations.
2. It follows established jurisprudence emphasizing the need for courts to monitor investigations in sensitive or high-stakes cases to safeguard the interests of justice.

Court’s Reasoning:

1. The court found that the primary relief sought by the petitioners—constituting an SIT—was rendered moot since an SIT had already been formed and was actively investigating the case.
2. The court acknowledged the seriousness of the matter, emphasizing the need for a thorough and expeditious investigation.
3. Recognizing the importance of timely justice, the court directed the SIT to expedite its investigation and file the final report at the earliest opportunity.

Conclusion:

The Kerala High Court disposed of the writ petition by instructing the existing SIT to complete the investigation promptly and submit the final report without delay. The court concluded that no further orders were required since the SIT was already operational and addressing the concerns raised by the petitioners.

Implications:

1. Reassurance of Fair Investigation: This judgment ensures that the investigation into Crime No. 133/2024 will proceed under a specialized and impartial body, thereby addressing public concerns about the efficiency of local law enforcement agencies.
2. Judicial Oversight: It highlights the judiciary’s role in ensuring that investigative processes remain unbiased and accountable, especially in cases of unnatural deaths or potential foul play.
3. Timeliness in Justice: By directing the SIT to file the final report promptly, the judgment underscores the need for swift justice in cases involving suspicious deaths.

Also Read – Supreme Court: Tribunal Cannot Disregard Medical Board’s 100% Disability Assessment; Enhances Compensation to ₹48.7 Lakh for Comatose Accident Victim