Supreme Court Orders CBI Probe in Sushant Singh Rajput Death Case: Legal Analysis

The Supreme Court of India, in its judgment dated August 19, 2020, ordered the transfer of investigation into the death of Bollywood actor Sushant Singh Rajput to the Central Bureau of Investigation (CBI). The judgment was delivered in the case of Rhea Chakraborty vs. State of Bihar & Others, where the petitioner sought the transfer of an FIR registered in Patna to Mumbai, where the alleged incident took place.

The case raised significant questions regarding jurisdiction, federalism, and the powers of state governments to transfer investigations to the CBI. The Court upheld the Bihar government’s decision to hand over the case to the CBI, reinforcing the importance of an impartial probe.

Background of the Case

On June 14, 2020, actor Sushant Singh Rajput was found dead in his Mumbai residence. The Mumbai Police initiated an Accidental Death Report (ADR) under Section 174 of the CrPC and conducted an inquiry. However, no FIR was registered.

On July 25, 2020, the deceased actor’s father, Krishna Kishor Singh, filed an FIR in Patna against Rhea Chakraborty and others under various sections of the IPC, including abetment of suicide (Section 306) and criminal breach of trust (Section 406). He alleged financial irregularities and mental harassment by the accused.

Rhea Chakraborty, the petitioner, approached the Supreme Court under Section 406 of the CrPC, seeking transfer of the FIR to Mumbai, arguing that Bihar Police had no jurisdiction.

Petitioner’s Arguments (Rhea Chakraborty)

The petitioner contended that:

• The entire cause of action arose in Mumbai, and hence, the Patna FIR was beyond Bihar Police’s jurisdiction.
• The Bihar government’s consent to transfer the case to the CBI was unlawful as only the Maharashtra government could authorize such a transfer.
• The Mumbai Police was already conducting an inquiry, and there was no need for an independent probe by Bihar Police or CBI.
• The case was politicized, and she was being unfairly targeted.

Respondents’ Arguments (State of Bihar & Others)

The respondents argued that:

• The Patna FIR was valid as it alleged offenses including criminal breach of trust that affected the complainant in Bihar.
• The Mumbai Police was conducting an inquiry, not an investigation, and had not registered an FIR.
• The Bihar government had the authority to request a CBI investigation under Section 6 of the Delhi Special Police Establishment (DSPE) Act.
• Since the case involved interstate ramifications, a CBI probe was necessary to ensure an impartial investigation.

Supreme Court’s Observations

The Supreme Court examined the jurisdictional and procedural aspects of the case, making the following key observations:

• The Patna FIR was legally valid as the complaint alleged criminal breach of trust and misappropriation of funds, which had consequences in Bihar.
• Section 174 of CrPC (inquiry into unnatural deaths) does not substitute a criminal investigation under Section 157.
• Jurisdictional objections should not prevent an impartial investigation.
• The Bihar government had the authority to transfer the case to the CBI.
• There were political allegations against both Maharashtra and Bihar governments, and hence, a CBI investigation was necessary.

Important Verbatim Observations by the Supreme Court

“When truth meets sunshine, justice will not prevail on the living alone but after life’s fitful fever, now the departed will also sleep well.”

“The Bihar Police committed no illegality in registering the FIR. At the stage of investigation, they were not required to transfer the FIR to Mumbai Police.”

“CBI investigation is in the interest of justice and will ensure credibility of the probe.”

Final Verdict

The Supreme Court ruled that:

• The Patna FIR was legally valid and Bihar Police had jurisdiction.
• The Bihar government’s request for a CBI probe was lawful.
• All future cases related to the unnatural death of Sushant Singh Rajput would be investigated by the CBI.
• The Mumbai Police must hand over all evidence collected during its inquiry to the CBI.

Impact of the Judgment

The Supreme Court’s decision set an important precedent regarding the role of federal agencies in high-profile criminal investigations:

• Ensured Fairness: The judgment ensured that the case was investigated independently, free from political influence.
• Clarified Jurisdiction Issues: It reinforced that criminal cases can have consequences beyond the place of occurrence.
• Established a Precedent: The case set a legal benchmark for transferring investigations in cases with interstate ramifications.
• Enhanced Public Confidence: The ruling reaffirmed the judiciary’s role in upholding justice without external pressures.

The judgment provided much-needed clarity on jurisdictional matters and reinforced the principle that justice must be free from political interference and administrative constraints.

Petitioner Name: Rhea Chakraborty.
Respondent Name: State of Bihar & Others.
Judgment By: Justice Hrishikesh Roy.
Place Of Incident: Mumbai, Maharashtra.
Judgment Date: 19-08-2020.

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