When the Police Investigation Is Callous, Justice Demands a Neutral Hand: Supreme Court Upholds CBI Probe into Suspicious Death of Real Estate Tycoon Linked to MP

Once FIR Has Been Registered and Investigation Is Found to Be Shoddy, the Truth Must Be Unearthed by CBI — Prospective Accused Cannot Choose Their Investigator — Delivering a strong message on the limits of state police accountability and the necessity of impartial investigation, the Supreme Court of India on April 23, 2025, in Ramachandraiah & Anr. v. M. Manjula & Ors. and D.A. Srinivas & Anr. v. M. Manjula & Ors. [2025 INSC 556], upheld the Karnataka High Court’s order directing a CBI investigation into the suspicious death of K. Raghunath, a prominent real estate businessman and close associate of former MP D.K. Adikeshavalu.

Rejecting the objections of the accused, the Court restored the focus on the shoddy SIT probe, highlighting the “grave irregularities, unexplored leads, and institutional gaps,” and concluded:

“The truth surrounding the death of K. Raghunath needs to be settled after a complete and fair investigation by the CBI which, in the facts and circumstances of the present case, has rightly been directed by the High Court.”

A Businessman Found Dead, A Family at War, and a Forensic Puzzle

On May 4, 2019, K. Raghunath was found hanging in a guest house room in Bengaluru. Though the death was recorded as a suicide, his widow Manjula and son alleged he had been pressured and lured to the location by Respondent No. 12 (D.A. Srinivas), son of the late MP, with whom Raghunath shared longstanding business ties.

The case deepened when a second will, allegedly signed by Raghunath in 2018 and registered posthumously in 2019, surfaced — naming Srinivas as the beneficiary of massive assets. This clashed with an earlier 2016 will in favour of Raghunath’s family. The forensic lab report later declared the 2018 will as fake.

Despite this, a Special Investigation Team (SIT) filed a ‘B’ summary report, suggesting no foul play. The Magistrate dismissed it outright, calling the report:

“Shoddy, perfunctory, and riddled with lapses... The SIT ignored glaring forensic contradictions and failed to even probe the death properly.”

Supreme Court: “Accused Have No Say in the Choice of Investigating Agency”

The appellants challenged the CBI probe on multiple grounds — lack of jurisdiction, alleged fabrication by the complainants, and the sanctity of the earlier SIT findings. But the Court found these arguments legally and morally untenable.

Quoting from the landmark decision in W.N. Chadha, the Bench emphasized:

“The accused has no right to dictate the manner or method of investigation, nor to interfere with the discretion of the investigating agency or the court.”

The Court dismissed the claim that the Magistrate's order directing further investigation was invalid:

“Once FIRs were registered and the accused themselves withdrew the challenge to their legality, the issue of jurisdiction stood closed.”

On the CBI’s Role: “A Rare and Exceptional Power Must Be Used Where State Fails”

While reaffirming that a CBI investigation is not automatic, the Court declared that this was a textbook case for invoking such jurisdiction. Relying on Pooja Pal v. Union of India and Vinay Tyagi v. Irshad Ali, the Court reiterated:

“Where state police fail in their duty, and when material facts are glossed over with no real effort to investigate, the constitutional courts are duty-bound to ensure justice is not derailed by institutional apathy.”

The Supreme Court took note of the forged will, the absence of autopsy rigor, and the refusal to test seized documents for handwriting and fingerprint evidence.

“The SIT’s failure to even identify or question the persons present at the scene that day reveals the superficial nature of its effort.”

 “When Truth Is at Stake, Investigation Must Rise Above Local Influence”

The Court upheld the High Court’s mandamus to the CBI and directed that:

• All case records be handed over within 15 days.

• The CBI complete the investigation within 8 months.

• Any chargesheet be filed before the competent CBI court in Karnataka.

“Justice cannot be a casualty to poor policing. When the truth has been buried under bureaucratic comfort or political weight, it becomes the solemn duty of constitutional courts to exhume it.”

This decision is a firm reiteration that CBI is not a substitute for the police — but a necessary remedy when the police substitute diligence with indifference.

Date of Decision: April 23, 2025