Failure to Register an FIR is a Violation of Fundamental Rights – Supreme Court’s Landmark Judgment on IIT Delhi Student Deaths

Summary of the Judgment

• Case Name: Amit Kumar & Ors. vs. Union of India & Ors.

• Date of Judgment: 24 March 2025

• Judges: Hon'ble Justice J.B. Pardiwala & Hon'ble Justice R. Mahadevan

• Advocates: Representation from the petitioners and respondents, including IIT Delhi and law enforcement agencies

• Acts & Sections:

  • Section 174 of the Code of Criminal Procedure (CrPC) (Inquest Proceedings)

  • Section 154 of the CrPC (First Information Report)

  • Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989

  • SC/ST (POA) Rules, 1995

• Cited Judgments:

  • Lalita Kumari vs. State of Uttar Pradesh (Mandatory FIR registration in cognizable offences)

  • P.K. Mohan Ram vs. B.N. Ananthachary (Analysis of documentary evidence)

  • Various other precedents related to caste-based discrimination and police obligations

Introduction

The Supreme Court of India, in its judgment dated 24 March 2025, addressed a highly sensitive issue regarding the deaths of two students from the Scheduled Caste community at the Indian Institute of Technology, Delhi (IIT Delhi). The judgment revolves around alleged caste-based discrimination, administrative lapses, and the failure of law enforcement agencies to register an FIR despite multiple complaints from the victims' families. This article critically analyses the decision and its implications for Indian legal professionals.

Background of the Case

The case stems from two tragic incidents at IIT Delhi: the deaths of students Ayush Ashna (on 08.07.2023) and Anil Kumar (on 01.09.2023). Both students were found dead in their respective hostel rooms under suspicious circumstances. Their families alleged foul play and caste-based discrimination, but law enforcement officials categorised the deaths as suicides due to academic stress.

The petitioners approached the Delhi High Court seeking a writ of mandamus for FIR registration under Section 154 of the CrPC and an independent inquiry into the alleged caste-based atrocities. However, the High Court rejected their plea, leading to an appeal before the Supreme Court.

Key Legal Issues

1. Non-Registration of FIR: A Breach of Legal Duty?

One of the foremost issues before the Supreme Court was whether the refusal of police authorities to register an FIR constituted a breach of their legal duty. The court examined Section 154 of the CrPC and reiterated the principles laid down in Lalita Kumari vs. State of Uttar Pradesh, which held that "registration of FIR is mandatory under Section 154 if the information discloses commission of a cognizable offence."

Key Judicial Observation:

"The failure to register an FIR despite prima facie evidence of a cognizable offence is a direct contravention of statutory obligations under CrPC and violates the fundamental rights of the victims’ families."

The Supreme Court criticised the police for treating the matter as an inquest proceeding under Section 174 CrPC instead of registering a formal criminal case.

2. Caste-Based Discrimination in Educational Institutions

The judgment also delves into the question of systemic caste-based discrimination in premier educational institutions. The Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, provides stringent provisions to address such discrimination. The petitioners submitted that both students had complained about discriminatory behaviour before their deaths, yet no preventive or remedial action was taken by IIT Delhi.

Key Judicial Observation:

"It is the duty of higher educational institutions to create an inclusive and harassment-free environment, particularly for students from marginalised communities. The allegations of caste-based discrimination, if substantiated, warrant immediate legal action and institutional reforms."

The court directed IIT Delhi to implement stricter anti-discrimination policies and ensure active participation of SC/ST cells in grievance redressal.

3. Role of Higher Educational Institutions in Student Welfare

The judgment highlights the accountability of IIT Delhi in addressing students' mental health and caste-related concerns. The court noted that despite the presence of an SC/ST Cell at IIT Delhi, there was no documented complaint mechanism followed by the students.

Key Judicial Observation:

"Mere existence of anti-discrimination cells is insufficient unless they actively function to protect students’ rights. Institutions must proactively engage in preventing discrimination and providing support to affected students."

4. Forensic and Circumstantial Evidence

The post-mortem reports stated that both deaths resulted from asphyxia due to hanging. However, discrepancies were noted in the victims’ families’ complaints, particularly concerning the presence of bloodstains and the condition of the bodies. The court observed that such inconsistencies should have warranted a deeper investigation rather than a summary closure under inquest proceedings.

Judgment and Directives

The Supreme Court issued the following directives:

1. Mandatory FIR Registration: The police must register an FIR in both cases and conduct a thorough criminal investigation.

2. CBI Inquiry: A Central Bureau of Investigation (CBI) probe was ordered to examine the circumstances leading to the students’ deaths and possible caste-based discrimination.

3. Institutional Reforms at IIT Delhi: The court directed IIT Delhi to establish a high-powered committee to review its policies on caste-based discrimination and student mental health.

4. National Task Force on Student Mental Health: The Union Government was instructed to constitute a National Task Force to address student mental health concerns and suicide prevention in higher educational institutions.

Implications

1. Strengthened Precedents on FIR Registration

Legal practitioners handling cases of discrimination and suspicious deaths can now cite this ruling to ensure mandatory FIR registration, reinforcing Lalita Kumari.

2. Expanded Scope of Institutional Accountability

The case sets a precedent for holding educational institutions accountable for student welfare and discrimination, which can be leveraged in future litigation on similar issues.

3. Emphasis on Victim-Centric Investigation

The ruling discourages law enforcement from prematurely concluding suicide in cases where caste-based discrimination is alleged, thereby mandating a more thorough investigative approach.

4. Strengthening the SC/ST (POA) Act Implementation

By upholding the need for stringent compliance with the SC/ST (Prevention of Atrocities) Act, this judgment reinforces legal protections for marginalised communities in educational institutions.

Conclusion

The Supreme Court's ruling in Amit Kumar & Ors. vs. Union of India & Ors. is a landmark decision in the intersection of criminal law, human rights, and education policy. By mandating a CBI inquiry, reinforcing institutional accountability, and addressing systemic discrimination, the judgment paves the way for significant legal and policy reforms. For Indian legal professionals, this case serves as a crucial precedent in advocating for the rights of marginalised communities and ensuring justice in cases of institutional negligence.