Karnataka High Court Hears PIL Alleging 74 Unnatural Deaths in Dharmasthala Buried Without Mandatory Procedure

In a case that peels back layers of opaque death investigations, the Karnataka High Court on Tuesday began examining a public interest litigation that claims at least 74 instances of unnatural deaths in the temple town of Dharmasthala were handled without following mandatory legal procedures. The plea, filed by the mother of a girl who was allegedly raped and murdered in the same region, paints a disturbing picture of bodies being buried hastily, often without inquests, post-mortems, or even basic identification, and calls for a court-monitored probe by a Special Investigation Team (SIT) to unearth the truth.

The Genesis of a Grave Allegation

The PIL traces its roots to an FIR registered on the complaint of a sanitation worker, who alleged that he had been instructed to bury the bodies of women and children in Dharmasthala over a period spanning nearly two decades—from 1995 to 2014. The mother’s petition now seeks to locate and exhume human remains from suspected mass burial sites, identify the victims through DNA matching, and determine the actual causes of death. It also demands the registration of 74 separate First Information Reports, each corresponding to a case documented in her representation to the authorities.

The matter came before a Division Bench of the Chief Justice and Justice K.S. Hemalekha, with advocate Vrinda Grover appearing for the petitioner. Grover wasted no time in highlighting what she called a “deeply disturbing pattern of unnatural deaths and disappearances” in and around the temple town, setting the stage for a probing judicial scrutiny of the state’s handling of these cases.

Blatant Violations of Statutory Procedure

Central to the petitioner’s argument is the alleged flagrant disregard for Section 174 of the Code of Criminal Procedure (CrPC) and the Karnataka (Investigation of Unnatural Deaths and Conduct of Inquests) Rules, 2004. Section 174 CrPC mandates that upon receiving information of an unnatural death—including suicide, accident, or homicide—the police must conduct an inquest and prepare a report. The Karnataka Rules further prescribe the timeline and manner in which such investigations must be carried out.

Grover submitted that in the 74 cases tabulated by the petitioner, these requirements were routinely ignored. “They [dead bodies] are buried immediately on the same date and some on the very next date. The location of the grave is not recorded… Victims are uniformly tabulated as unknown persons, without their age group and gender,” she told the court. Even more startling was the assertion that in three cases, the police had not assigned Unnatural Death Report (UDR) numbers at all, while in others, the manner of death was cursorily noted as “suicide” without specifying whether it was by hanging or any other means.

The counsel drove home the gravity of the lapses by citing specific instances. In one case, an unidentified woman was found dead in a lodge; the police registered it as murder and informed the town panchayat the very next morning, yet the body was cremated shortly thereafter. “Where is the inquest, post-mortem, and procedure under Section 174 CrPC and rules regarding Unnatural Deaths?” Grover questioned. Another case involved a 25‑ to 30‑year‑old woman found hanging in a nearby forest, whose death was labelled a suicide and the body buried the next day without any forensic examination. “Was she hanged after homicide? We will never know because on the very next day the body is buried, no inquest is done,” the counsel argued. In yet another instance, the UDR was “erased from the record altogether,” while a 35‑year‑old man found dead in a guest house run by the Dharmasthala Trust remained unidentified, with no apparent effort made to trace his identity.

The SIT Steps In

The Karnataka government, recognizing the seriousness of the allegations, had constituted a Special Investigation Team on July 19, 2025, to look into the matter. The notification, which Grover read out to the court, declares the SIT as a police station, designates a senior officer as the Station House Officer, and empowers the team to conduct investigations under the Bharatiya Nyaya Sanhita (BNS) and submit final reports. The SIT is also mandated to comprehensively investigate all cases related to the controversy, including those registered in other police stations, and to periodically report its progress to the state.

The petitioner’s plea seeks a writ of mandamus directing the SIT to register the 74 separate FIRs and to file monthly status reports before the High Court. Grover emphasized that the SIT’s mandate includes the identification of witnesses and action against public officials who flouted the mandatory procedures while registering UDRs. The court has thus far allowed the SIT to proceed, but the mother’s petition insists that the investigation must remain under judicial watch to prevent any further cover‑up.

A Pandora’s Box of Legal Concerns

The current hearing is not the first time the Karnataka High Court has grappled with the Dharmasthala mass burial allegations. In a connected matter, the court had earlier orally observed that exhuming human remains could open a “Pandora’s box,” as more people might approach the court with claims of having seen bodies and seek similar investigations. This observation underscores the delicate balance between the need for a thorough probe and the potential for an avalanche of unverifiable claims.

From a legal standpoint, the case raises fundamental questions about the rule of law in death investigations. The procedural safeguards under Section 174 CrPC and the Karnataka Rules are not mere technicalities; they are designed to ensure that every unnatural death is properly documented, the cause of death is scientifically determined, and the rights of the deceased and their families are protected. When these safeguards are bypassed, the entire criminal justice system is undermined—homicides may go undetected, families may never know the truth, and public faith in law enforcement erodes.

The petitioner’s demand for exhumation and DNA identification also brings into focus the legal framework governing the disposal of unclaimed bodies. Even in cases where a body is unclaimed, the police cannot simply dispose of it without following the prescribed procedure. The failure to record the location of graves, the age and gender of victims, and the manner of death not only violates statutory rules but also amounts to a denial of the right to dignity under Article 21 of the Constitution.

Rippling Effects on Investigative Practices

The mass burial case in Dharmasthala is poised to have a significant impact on how unnatural death investigations are conducted across Karnataka. If the court finds merit in the allegations, it could mandate systemic reforms, including stricter compliance audits, training for police personnel on the Karnataka Rules, and the creation of a centralized database of UDRs to prevent records from being “erased.” The observation that even bodies found in guest houses—where identity records are usually maintained—were buried as unknown persons further highlights the need for better coordination between police and other agencies.

For legal practitioners, the case serves as a stark reminder of the importance of insisting on procedural compliance right from the filing of a UDR. Defense lawyers may find new avenues to challenge the prosecution’s narrative in cases where inquests were perfunctory or post‑mortems were omitted. Public prosecutors, on the other hand, will need to ensure that the investigating agencies adhere to the letter of the law to avoid fatal flaws in trial.

The Road Ahead

The State sought time during the hearing, citing the unavailability of the Advocate General, and the Bench posted the matter for further hearing on August 24. By then, the SIT is expected to have made some progress in its investigation, and the court will likely scrutinize the steps taken so far.

The PIL by the mother of the alleged rape‑and‑murder victim has transformed into a broader crusade for accountability. As the Karnataka High Court delves deeper into the 74 unnatural deaths, the spotlight is not only on the temple town of Dharmasthala but on the entire edifice of criminal investigation in the state. The outcome may well determine whether the “Pandora’s box” yields long‑suppressed truths or becomes a cautionary tale of investigative apathy.