The Supreme Court held that the procedural safeguards laid down in People’s Union for Civil Liberties v State of Maharashtra (2014) for police encounters are binding and must be enforced regardless of whether the victim or their family initiates the complaint.

A Public Interest Litigation (PIL) at the Assam High Court sought an independent investigation into alleged fake encounters in the state. It noted that 80 incidents had resulted in 28 deaths and 48 injuries across the state. The State admitted that 171 police encounters occurred between May 2021 and August 2022, causing 56 deaths and 145 injuries. The High Court dismissed the PIL as premature and vague.

The Supreme Court set aside the High Court order. It directed the Assam Human Rights Commission to conduct an independent inquiry into the allegations. It held that PUCL guidelines (2014) — requiring mandatory FIRs, independent investigation by the CID or other stations, magisterial inquiry for deaths, forensic analysis and informing human rights commissions are not contingent on direct victim participation. Further, encounters resulting in death must be investigated fairly and mere ‘self-defence’ cannot be the only justification.

Judgement Date: 28 June 2025

Citations: 2025 INSC 785 | 2025 SCO.LR 5(4)[20]

Bench: Surya Kant J, N.K. Singh J

 

Read the Judgement here

Case Comment

The Supreme Court set aside the High Court order. It directed the Assam Human Rights Commission to conduct an independent inquiry into the allegations. It held that PUCL guidelines (2014) — requiring mandatory FIRs, independent investigation by the CID or other stations, magisterial inquiry for deaths, forensic analysis and informing human rights commissions are not contingent on direct victim participation. Further, encounters resulting in death must be investigated fairly and mere ‘self-defence’ cannot be the only justification.

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Key words/phrases: Assam High Court order set aside—extra judicial killings—PUCL guidelines binding—mandatory FIRs—independent investigation—magisterial inquiry—procedural safeguards not victim-dependent—fair probe in encounter deaths

 

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