The High Court of Karnataka has issued a significant directive clarifying the scope of police investigations in cases of unnatural death, ruling that an inquest report prepared by an Executive Magistrate cannot be treated as a final report or a substitute for a comprehensive police investigation. In a judgment delivered by Justice Suraj Govindaraj, the court mandated that jurisdictional police must complete their probe and submit a final report to the relevant Magistrate, ensuring the right of victims and complainants to file protest petitions.

This ruling stems from a writ petition filed by Sri Subbaiah, who sought judicial intervention after the death of one Santhosh on December 9, 2023. Although an Unnatural Death Report (UDR) was registered and an inquest was conducted by the Executive Magistrate the following day, the police had failed to file a final report before the jurisdictional court, leaving the petitioner without the necessary documentation to challenge the findings. The court’s decision establishes a clear procedural mandate for police officers across the state, emphasizing that the inquest process is merely an aid to the broader criminal investigation.

Clarifying the Scope of Procedural Duties

Addressing the confusion regarding the finality of UDR proceedings, Justice Govindaraj observed that the role of an Executive Magistrate during an inquest is restricted to fact-finding regarding the cause of death. By drawing on the landmark judgment of the Madras High Court in Manohari v. District Superintendent of Police , the bench highlighted that police officers have often misinterpreted the statutory requirements of the Code of Criminal Procedure (CrPC) and the recently enacted Bharatiya Nagarik Suraksha Sanhita (BNSS).

The court reiterated that the inquest report serves a limited purpose, noting, "The Inquest Report prepared under Section 174 of the CrPC is not a final report . It merely forms part of the materials collected during the course of investigation. Whether the First Information Report is registered before or after the preparation of the Inquest Report would not affect its validity." The bench further clarified that the inquest findings do not override the responsibility of the police to conduct an independent and thorough investigation into the circumstances of a death.

The ruling underscores that regardless of whether the final report is a positive charge-sheet or a closure report, it must be submitted before the jurisdictional Judicial Magistrate under Section 173(2) of the CrPC—or the corresponding provision in the new criminal law framework. The court emphasized that the Executive Magistrate’s findings cannot be equated with this mandatory final reporting process.

Ensuring Accountability in Death Inquiries

A key concern addressed by the court was the limitation imposed on complainants when police fail to finalize their investigations. In instances where the police file a closure report, the complainant is entitled to notice, which allows them to pursue legal recourse through a protest petition. Without a formal final report, such rights become illusory. By mandating that the police file these reports, the court has ensured that individuals like the petitioner have the opportunity to seek judicial oversight if they are dissatisfied with the police’s investigative conclusions.

Justice Govindaraj’s order explicitly rejects the state’s contention that the investigative process concludes upon the submission of the inquest report to the Executive Magistrate. The court stated, "The Executive Magistrate's Inquest Report cannot be treated as a substitute for, or equated with, the final report contemplated under Section 173(2) of the CrPC ." This clear distinction is expected to streamline police procedures and enhance transparency in the investigation of unnatural deaths.

Implementing Statewide Compliance

To ensure that this interpretation of the law is applied consistently, the court directed the Director General of Police to disseminate the legal principles established in the Manohari judgment to all investigating officers throughout Karnataka. This initiative includes the distribution of the judgment in both English and Kannada to ensure clarity at the ground level. The Director General of Police is further required to submit a formal compliance report to the High Court within four weeks.

The court has also scheduled a follow-up hearing for August 25, 2026, to monitor the progress of the investigations and ensure that the directives are being honored by the police department. This proactive stance reflects the judiciary's commitment to upholding procedural integrity and preventing the erosion of the rights of citizens who seek justice in cases involving suspicious or unnatural deaths.

As the legal landscape shifts under the new criminal codes, the court reaffirmed that these procedural mandates remain applicable under Section 194 of the Bharatiya Nagarik Suraksha Sanhita, 2023, ensuring that the transition does not undermine the standard of accountability required from the police. For the petitioner, the High Court’s order provides a definitive pathway to progress, as the Yesaluru police are now compelled to complete their investigation and submit the requisite final report to the Additional Civil Judge and JMFC Court in Sakleshpura, thereby opening the door for the petitioner to exercise his right to contest the findings.