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2025 Supreme(Kar) 2363

IN THE HIGH COURT OF KARNATAKA AT BENGALURU
D.K. Singh, Tara Vitasta Ganju, JJ.
M/S. DNA Entertainment Networks Private Limited – Petitioner
Versus
State Of Karnataka Represented By The Chief Secretary - Respondent
Writ Petition No. 22323 of 2025 (GM-RES)
Decided On : 21-11-2025

Advocates Appeared:
For the Petitioner:Sri. B.K.Sampath Kumar, Senior Counsel Along With Sri. Suraj Sampath., Advocate
For the Respondent:Sri. K.Shashikiran Shetty, AG Along With Smt. Avishka Vaishnav, Advocate, Smt. Anukanksha Kalkeri, HCGP

A Commission of Inquiry can conduct fact-finding without infringing on an individual's rights when not investigating personal conduct or making prejudicial findings.

Headnote:(A) Commissions of Inquiry Act, 1952 - Sections 3(1), 8(b), and 8(c) - Writ petition challenging the report of One Member Commission regarding a stampede during victory celebrations of a sports team, resulting in casualties - Petitioner contends violation of rights to cross-examine and produce evidence. (Paras 1, 21, 32)

(B) Principles of Natural Justice - The Commission was set up as a fact-finding body and did not inquire into individual conduct; thus, provisions for cross-examination were not triggered. (Paras 23, 30)

Facts of the case:
The petitioner, a media company, organized victory celebrations for a sports team which led to a deadly stampede due to inadequate crowd control and lack of permissions, resulting in 11 deaths and numerous injuries. (Paras 1, 10)

Findings of Court:
The petitioner did not formally seek permission for the event, leading to overwhelming crowd conditions that caused the tragedy. The report of the Commission was deemed valid as its purpose was fact-finding, not to prejudge conduct. (Paras 13, 34)

Issues: Whether the Commission’s inquiry violated the petitioner's rights and whether the report could be quashed based on assumptions of adverse outcomes.

Ratio Decidendi: The court held that the Commission of Inquiry Act's provisions do not apply as the report was a factual investigation, and the petitioner had not acted timely to ensure rights were protected. (Paras 21, 26)

Result: Writ petition dismissed.

Table of Content
1. challenge to the report of the commission of inquiry (Para 1 , 2)
2. details of the victory celebrations and crowd management (Para 3 , 4 , 5 , 6 , 7 , 8 , 12 , 14)
3. suo motu petition regarding the tragedy and commissions established (Para 9 , 10 , 11 , 16 , 17 , 18)
4. arguments regarding the rights of the petitioner in the inquiry (Para 20 , 21 , 22 , 23 , 24 , 25 , 26)
5. assessment of the inquiry and dismissal of petition (Para 28 , 33 , 34)
6. final dismissal of the writ petition (Para 35)

ORDER :

D K SINGH, J.

The petitioner-M/s.DNA Entertainment Networks (for short 'the DNA') - a Media Company incorporated in the year 2005 under the provisions of the Companies Act, 1956, (for short 'the Act') has filed this writ petition challenging the report submitted by the Hon'ble Mr. Justice John Michael Cunha (Retd.), One Member Commission appointed by the State Government vide notification dated 05.06.2025 under Section 3 (1) of the Commission of Enquiry Act , 1952 in respect of the unfortunate incident on 04.06.2025, during the victory celebrations of the Royal Challengers Bengaluru in Indian Premier League 2025. Sadly, 11 people had died and several got grievously injured in the unfortunate and tragic incident (stampede).

2. The prayers sought for in the writ petition are extracted hereunder :-

"i) Issue a Writ of Certiorari or any other appropriate Writ, Order or Direction quashing the impugned Report submitted by the 3rd Respondent on 11.07.2025.

ii) Issue a Writ of Mandamus or any other appropriate Writ, Order or Direction directing the Respondents to furnish all the documents as sought for in the Application dated 22.07.2025 made by Mr. Sunil Mathew on behalf of the Petitioner vide Annexure G.

iii) Direct the Respondents to pay the costs of this Petition."

3. Brief facts of the case are as under :-

Royal Challengers, Bengaluru ( for short 'the RCB' is a Bengaluru based T20 Cricket team owned and operated by Royal Challengers Sports Private Limited ('the RCSPL'). The RCSPL is a company incorporated under the provisions of the Companies Act, 1956. RCB participates annually in the Indian Premier League ('the IPL') and Women's Premier League ('the WPL') tournaments organized by the Board of Control for Cricket in India (for short 'the BCCI').

4. Since 2008, the RCSPL has engaged DNA, the petitioner herein, a Media and Management Company based in Bengaluru, which has been acting as the turnkey event management service provider for RCB.

5. The entire responsibility of conceptualizing, planning, coordinating and executing all events and all activities have been comprehensively outsourced by RCSPL to DNA. DNA acts as an agent of RCSPL in respect of events across India, including cricket matches and other functions, and is responsible for various aspects for any such event including security and permissions at Chinnaswamy Stadium.

6. The latest turnkey event management agreement between RCSPL and DNA is dated 14.03.2025. There is a statement of work in the turnkey event management agreement dated 14.03.2025, which expressly identifies "Security Services" and "Permissions" as part of the scope of services to be provided exclusively by DNA.

7. On 03.06.2025, the Final Match of the Indian Premier League, 2025 took place at Narendra Modi Stadium in Ahmedabad, Gujarat between Royal Challengers Bengaluru (RCB) and Punjab Kings (PBKS). RCB emerged victorious in the Final Match of IPL 2025.

8. The petitioner-DNA, had conceived the victory celebrations on 04.06.2025 to be held at Chinnaswamy Stadium, Bengaluru.

9. As per the respondents, the victory celebrations at Chinnaswamy Stadium were planned without obtaining the required prior approvals and permissions, resulting in the gathering of huge, unregulated crowd at the venue.

10. The Director General and Inspector General of Police from Bengaluru and the Commissioner of Police, City of Bengaluru submitted their reports stating that on the same day that 11 people died and more than 50 were






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