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Amit Kumar v. Union of India

Criminal Appeal · 2025 INSC 384Decided 24 Mar 2025
Crl.A. No.-001425-001425 - 2025 (arising from SLP (Crl) No. 13324 of 2024)
Justice J.B. Pardiwala

Background

Two students at IIT Delhi died by suicide, and their parents (the appellants) sought registration of an FIR to investigate the circumstances, suspecting foul play and possible caste-based discrimination (invoking the SC/ST Prevention of Atrocities Act). The police treated the deaths only as matters for an inquest under Section 174 CrPC (which merely determines the apparent cause of death) and refused to register an FIR despite repeated written complaints to the police station and the Deputy Commissioner of Police. The Delhi High Court declined to direct FIR registration, prompting this appeal to the Supreme Court.

Decision Breakdown

The Supreme Court drew a sharp distinction between an inquest under Section 174 CrPC, a limited inquiry only into the apparent cause of death, and an FIR under Section 154 CrPC, which is mandatory whenever information discloses a cognizable offence and which alone triggers a full criminal investigation into who is responsible and why. It held that police have no discretion to substitute an inquest for FIR registration or to conduct an unauthorized "preliminary inquiry" to screen out a complaint before registering it, when the information discloses a cognizable offence. Applying this, the Court directed the Deputy Commissioner of Police (South-West Delhi) to register FIRs based on the parents' complaints and assign an officer of at least Assistant Commissioner rank to investigate. Recognising the wider, recurring problem of student suicides, the Court also issued institutional directions, including a requirement that police diaries record all cognizable-offence information regardless of whether an FIR is registered, and constituted a National Task Force to study and recommend reforms addressing student mental health and suicide prevention in higher educational institutions.

Lesson Learnt

Police cannot lawfully treat a suspicious death merely as a Section 174 inquest matter and refuse to register an FIR when the information given discloses a cognizable offence: FIR registration in such circumstances is mandatory, not discretionary, and citizens facing such refusal can seek a writ of mandamus compelling it.

Official source (sci.gov.in)View Judgment (PDF)

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