Hansura Bai v. Hanuman Prasad Meena, 2025
The Court is holding high-level officers personally accountable, which could redefine institutional liability in custodial crime cases.
Judgement Details
Court
Supreme Court of India
Date of Decision
23 September 2025
Judges
Justice B.V. Nagarathna & Justice R. Mahadevan
Citation
Acts / Provisions
Facts of the Case
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Deva Pardhi, a 26-year-old tribal man, died in police custody in Madhya Pradesh after being arrested for alleged theft.
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His uncle, Gangaram Pardhi, arrested along with him, was the sole eyewitness to the alleged torture.
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MP police claimed Deva died of a heart attack, but the family alleged custodial torture and murder.
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On May 15, 2025, the Supreme Court transferred the probe to the CBI, ordering it to arrest the accused officers within a month.
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Despite this, two police officers, Sanjit Singh Mawai and Uttam Singh Kushwaha, remained untraced and unarrested.
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Deva's mother, Hansura Bai, filed a contempt petition for failure to comply with the court’s directions.
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The eyewitness, Gangaram, remains in judicial custody, where he has allegedly faced assault and harassment.
Issues
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Whether the CBI failed to comply with the Supreme Court’s May 15 direction to arrest the accused officers?
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Whether the inaction constitutes willful disobedience warranting contempt proceedings?
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Whether the CBI and jail authorities failed in ensuring the safety of eyewitness Gangaram Pardhi, who was allegedly assaulted in custody?
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To what extent the State and CBI can be held accountable for protecting or shielding the accused?
Judgement
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The Court has directed the CBI to file affidavits and a status report by September 26, 2025.
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It was indicated that contempt charges may be framed against the CBI Director, Chief Secretary of MP, and the Additional SP in charge.
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It was warned CBI and prison authorities to ensure no harm befalls the eyewitness Gangaram Pardhi.
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It was Stated it would drop contempt if arrests are made within 2 days.
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The Rejected the plea of helplessness from the CBI.
Held
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The Court found prima facie contempt in failure to arrest the accused despite a clear order.
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The CBI's plea that the accused are absconding was rejected as inadequate, possibly masking complicity.
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The Serious warning issued regarding custodial safety of the eyewitness.
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The CBI was cautioned that it would be held personally responsible for any harm to Gangaram Pardhi.
Analysis
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The Court strongly indicated that state complicity or institutional cover-ups will not be tolerated.
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Justice Nagarathna’s remarks reflect judicial intolerance toward failure of accountability in custodial death cases.
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The proceedings emphasize the Supreme Court’s role as a constitutional guardian to uphold:
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Rule of law
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Protection of fundamental rights, especially of vulnerable tribal citizens
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The case underscores the growing judicial scrutiny of custodial deaths, CBI conduct, and lack of transparency.
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The Court is holding high-level officers personally accountable, which could redefine institutional liability in custodial crime cases.