CBI to Investigate Why wife of Chhattisgarh Senior Judicial Officer was Killed?

In a landmark decision aimed at ensuring a fair and impartial investigation, the Supreme Court of India has directed the Central Bureau of Investigation (CBI) to investigate the death of Ranjana Diwan, the wife of a senior judicial officer in Chhattisgarh. The case has attracted significant attention due to the involvement of a judicial officer, raising concerns about bias and influence over the investigation conducted by the local police.

Background of the Case

Ranjana Diwan, a young woman from Chhattisgarh, married Manvendra Singh, an Additional District Judge, in 2014. Singh had been appointed to the Chhattisgarh Higher Judicial Service in 2013. In May 2016, Diwan tragically passed away under circumstances that were initially reported as a suicide. However, her family, consisting of her mother and brother, suspected foul play and found inconsistencies in the investigation conducted by the local police.

The appellants—Ranjana's mother and brother—received a phone call informing them of Ranjana’s death, but were not provided with the post-mortem report. The police quickly filed a closure report, treating the incident as a straightforward suicide, a conclusion that did not satisfy Ranjana's family. Suspecting that the circumstances of her death were suspicious, they sought a more thorough investigation.

The appellants raised their grievances before the Chhattisgarh High Court, filing a writ petition in search of a fair investigation. In May 2023, the High Court disposed of the petition, suggesting that the appellants could file a complaint before a Magistrate under Section 156(3) of the Code of Criminal Procedure (CrPC). The section allows the Magistrate to direct an investigation by the police. However, the family’s concerns persisted, especially regarding the fairness of any investigation conducted under the influence of a serving judicial officer.

Appellants’ Concerns and Supreme Court's Response

Before the Supreme Court, the petitioners emphasized their apprehensions that a fair investigation could be undermined due to the respondent, Manvendra Singh, being a senior judicial officer. They pointed out that the post-mortem report indicated six antemortem injuries on Ranjana's body, for which there was no adequate explanation provided by the investigating authorities. This added to the family’s suspicion that her death was not a simple case of suicide but involved foul play, potentially linked to her husband or others.

The State of Chhattisgarh argued that a fair investigation had already been conducted at the highest levels and claimed that there was no need for further inquiry. However, the petitioners disagreed, contending that the influence of respondent no.7—Manvendra Singh—compromised the investigation. To ensure justice, they requested an impartial and transparent probe.

Solicitor General of India, Tushar Mehta, intervened during the proceedings and suggested that the Court might consider appointing a high-level Special Investigation Team (SIT) or, alternatively, direct the CBI to investigate the case. He emphasized that such a move would not only provide credibility to the investigation but would also restore public confidence, ensuring that justice is seen to be done.

Supreme Court Orders CBI Investigation

In a significant ruling, the Supreme Court bench, consisting of Justices Vikram Nath and Prasanna B Varale, acknowledged the gravity of the situation and the need for a transparent investigation. The Court agreed with the appellants that there were valid concerns regarding bias and undue influence on the local police. The Court deemed it fit to entrust the CBI with the investigation, considering that the respondent, Manvendra Singh, was a serving judicial officer, whose status could potentially affect the impartiality of the local investigation.

The Supreme Court's ruling highlighted that the investigation needed to dispel any doubts in the minds of the appellants and the general public. By transferring the case to the CBI, the Court ensured that the investigation would be free from local influences and conducted with complete fairness and transparency.

Key Observations by the Court

The Court made several critical observations while passing the order. It acknowledged that:

• The appellants had raised legitimate concerns regarding bias and undue influence on the State’s police machinery.

• The investigation so far had failed to adequately explain the six antemortem injuries found on Ranjana’s body.

• Given the influence and power of the respondent as a senior judicial officer, transferring the investigation to the CBI would instill confidence in the investigation and the justice system as a whole.

The Court also noted that while directing the CBI investigation, it had not expressed any opinion on the merits of the case. The CBI was instructed to conduct its investigation independently, without being influenced by any of the Court’s observations.

Directions to CBI and State Cooperation.

The Supreme Court directed the CBI to carry out its investigation expeditiously, considering the fact that the incident occurred in 2016, and a significant amount of time had already elapsed. Additionally, the State of Chhattisgarh was instructed to fully cooperate with the CBI, providing all necessary documents, papers, and support required for the investigation.

The Court also emphasized the importance of ensuring that justice is delivered not only to the aggrieved family but also in upholding the fundamental right of every citizen to receive a fair and impartial investigation.

Implications of the Judgment

This judgment is a vital step toward reinforcing public trust in the judicial and law enforcement systems. By involving the CBI, the highest investigative agency in India, the Supreme Court has underscored its commitment to ensuring transparency, fairness, and justice, especially in cases where influential individuals may be involved.

Moreover, the decision reflects the judiciary's recognition of the potential for bias or influence in cases involving high-ranking officials or judicial officers. The Court's approach in transferring the investigation sends a strong message that no one, not even those within the judiciary, is above the law and that justice must be delivered impartially.

The Supreme Court's decision to transfer the investigation of Ranjana Diwan’s death to the CBI is a testament to its dedication to ensuring a fair and unbiased judicial process. By acknowledging the petitioners’ concerns and addressing the potential for undue influence in the local investigation, the Court has reaffirmed its role as the guardian of justice and the rights of citizens. As the CBI proceeds with the investigation, this case serves as a reminder that the judiciary remains steadfast in its mission to uphold the rule of law, ensuring that justice is both done and seen to be done.

Case Title: Mandakini Diwan and Anr. v. The High Court of Chhattisgarh & Ors.