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Sukdeb Saha v. The State of Andhra Pradesh & Ors.

Criminal Appeal · 2025 INSC 893Decided 25 Jul 2025
Crl.A. No.-003177-003177 - 2025 (arising out of SLP(Crl.) No. 6378 of 2024)
Justice Vikram Nath · Justice Sandeep Mehta

Background

The appellant's 17-year-old daughter, staying at a hostel in Visakhapatnam while preparing for the NEET medical entrance exam at a coaching institute, died in July 2023 under suspicious circumstances after allegedly falling from the hostel's third floor and later dying in hospital following delayed medical treatment. Dissatisfied with the local police investigation (which he alleged involved non-cooperation, contradictory statements, and suppression of evidence) the father sought transfer of the investigation to the CBI, but the Andhra Pradesh High Court rejected his plea.

Decision Breakdown

The Supreme Court held that transfer of investigation to the CBI is an extraordinary remedy reserved for rare cases where it is necessary to ensure a fair, credible probe and to maintain public confidence in the justice system, and found this to be exactly such a case given the family's persistent, credible allegations of non-cooperation and evidence suppression by local authorities. It quashed the High Court's order and directed the case to be transferred to the CBI, with a report to be filed within four months. Recognizing that the case reflected a much larger nationwide problem, the Court (in a substantial "Part B" of the judgment) went further and laid down comprehensive, binding guidelines for all educational institutions across India (schools, colleges, coaching centres, and hostels) covering mandatory mental health policies, counselling access, staff training, and grievance redressal, along with directions requiring states to frame regulatory rules for coaching centres within two months and requiring the Union Government to file a compliance affidavit within 90 days.

Lesson Learnt

Courts can order a CBI transfer of investigation when there is a credible, persistent pattern of non-cooperation or suppression by local police that threatens a fair probe; more broadly, this judgment established nationwide, court-mandated mental health safeguards for students at all educational institutions, showing how a single family's tragedy can lead to systemic protective directions for millions of students.

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

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