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2025 Supreme(SC) 1112

VIKRAM NATH, SANDEEP MEHTA
Sukdeb Saha – Appellant
Versus
State of Andhra Pradesh – Respondent


Advocates appeared:
For the Petitioner(s): Mr. Joydeb B. Saha, Adv. Mr. S Ramamoorthy, Adv. Mr. S Senthil Elangovan, Adv. M/s V. Maheshwari & Co., AOR
For the Respondent(s): Mr. Rajkumar Bhaskar Thakare, A.S.G. Mr. Mukesh Kumar Maroria, AOR Mr. Vivek Gupta, Adv. Mr. Rohit Khare, Adv. Mr. Padmesh Mishra, Adv. Mr. Merusagar Samantaray, Adv. Mr. Tanmay Mehta, Adv. Ms. Prerna Singh, Adv. Mr. Guntur Pramod Kumar, AOR Mr. Dhruv Yadav, Adv. Mr. P. Santhosh Kumar, Adv. Mr. P. Venkatraju, Adv. Mr. Sravan Kumar Karanam, AOR Mr. Y. Raja Gopala Rao, AOR Mr. B. Mohan, Adv. Mr. Akshay Singh, Adv. Ms. Sanjana Jain, Adv. Ms. Manasi Chatpalliwar, Adv. Mr. Pranav Proothi, Adv. Mr. Pulkit Agarwal, AOR Mr. Sudhanshu Kaushesh, Adv. Mr. M Srinivas R Rao, Adv. Mr. Abid Ali Beeran P, AOR Mr. Sarath S Janardanan, Adv. Mr. Saswat Adhyapak, Adv. Ms. Namita Kumari, Adv. Mr. Anand Varma, AOR Ms. Apoorva Pandey, Adv. Mr. Kunal Mimani, AOR Mr. Abhinav Rana, Adv.

Judgement Key Points

Certainly. Based on the provided legal document, here are the key points summarized without referencing specific case law:

  • The Supreme Court transferred the investigation of an unnatural death case involving a student to the CBI due to concerns over the fairness and thoroughness of the local investigation, citing irregularities and potential bias (!) (!) .

  • The investigation into the student's death was marked by procedural lapses, including inadequate examination of forensic evidence, discrepancies in CCTV footage, and possible suppression of critical medical and forensic reports (!) (!) (!) (!) .

  • There were significant concerns regarding the medical treatment and forensic procedures, including the destruction of vital viscera before completion of forensic analysis, which compromised the integrity of the investigation (!) .

  • The investigation revealed inconsistencies between the medical reports, forensic findings, and the timeline of events, raising suspicions about the accuracy of the initial conclusions, especially the theory of suicide (!) (!) .

  • The Court emphasized that investigations must be conducted fairly, transparently, and effectively, and that transfer to a central agency like the CBI is warranted only in exceptional circumstances where local investigations are tainted or inadequate (!) (!) .

  • The Court identified systemic issues in the mental health support framework within educational institutions, highlighting the urgent need for comprehensive policies, guidelines, and institutional safeguards to prevent student suicides and promote mental well-being (!) (!) (!) .

  • The Court issued broad, binding guidelines for all educational institutions, including the appointment of qualified mental health professionals, training of staff, establishment of reporting mechanisms, and proactive measures to ensure student safety and mental health support [p_112–p_126].

  • It directed the relevant authorities to implement registration, protection norms, and grievance redressal mechanisms for coaching centres and educational institutions, with oversight by district-level committees [p_128–p_130].

  • The Court underscored the importance of safeguarding students' mental health as a fundamental aspect of their right to life and dignity, emphasizing international obligations and the need for legislative and regulatory frameworks [p_106–p_110].

  • The judgment mandated immediate action to improve mental health infrastructure and oversight in educational environments, with a follow-up on compliance and implementation of these guidelines and measures (!) (!) .

  • The Court clarified that the observations made are not to influence the merits of the case but are aimed at ensuring an impartial investigation and systemic reforms to prevent future tragedies (!) .

  • The investigation and related proceedings are to be conducted with fairness and transparency, and the investigation file, including all evidence, is to be transferred to the CBI for an independent and comprehensive inquiry (!) .

Please let me know if you need further elaboration or assistance on specific aspects.


JUDGMENT :

SANDEEP MEHTA, J.

Table of Contents

(I)

INTRODUCTION:

(II)

PART A:

(i) Facts of the Case:

(ii) Submissions on behalf of the Appellant:

(iii) Submissions on behalf of the Respondents:

(iv) Discussion & Analysis:

(v) Conclusion:

(III)

PART B:

(i) Background:

(ii) Right to Mental Health:

(iii) Guidelines:

(iv) Directions:

(I) INTRODUCTION

1. Heard.

2. Leave granted.

3. The present appeal arises from the judgment and order dated 14th February, 2024, passed by the High Court of Andhra Pradesh at Amravati1 [Hereinafter being referred to as ‘Andhra Pradesh High Court’] in Writ Petition No. 25381 of 2023, whereby the High Court rejected the appellant’s prayer, seeking transfer of the investigation of FIR No. 148 of 2023 to the Central Bureau of Investigation.2 [Hereinafter being referred to as “CBI” The aforesaid FIR was registered following the tragic, unnatural death of the appellant’s 17-year-old daughter, Ms. X, who was undergoing coaching for the National Eligibility-cum-Entrance Test (NEET) examination at Aakash Byju’s Institute, Vishakhapatnam. She was staying in a Hostel when the unfortunate incident occurred on 1

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