Supreme Court Upholds Human Rights Commission Order Against Police Officer for Denial of Justice

The Supreme Court of India recently delivered a significant judgment in the case of Pavul Yesu Dhasan vs. The Registrar, State Human Rights Commission of Tamil Nadu & Ors., upholding the order of the State Human Rights Commission that directed compensation for violation of human rights by a police officer. The case highlights the fundamental rights of citizens when approaching police stations and the duty of police officers to treat complainants with dignity.

The case originated when the third respondent visited the Srivilliputhur Town Police Station to lodge a complaint along with his parents. The Sub-Inspector refused to accept the complaint, stating that since the transaction occurred at three different places, he couldn’t accept it without the Inspector’s approval. The complainant’s mother then tried contacting the appellant Inspector, who not only refused to register the FIR but also used ‘very objectionable language’ while speaking to her.

The State Human Rights Commission found this conduct to be a violation of human rights and ordered compensation of ₹2,00,000 to be paid to the complainant, with liberty to recover the amount from the appellant police officer. The police officer challenged this order before the Supreme Court, arguing that refusal to register an FIR doesn’t constitute a human rights violation.

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The Supreme Court bench comprising Justices Abhay S. Oka and Ujjal Bhuyan rejected this argument, stating: “Under clause (d) of Section 2 of the Act, ‘human rights’ means the rights relating to life, liberty, equality and dignity of the individual guaranteed by the Constitution. All that the third respondent and his parents wanted was registration of the FIR. Every citizen of India who goes to a Police Station to report commission of an offence deserves to be treated with human dignity. That is his fundamental right under Article 21 of the Constitution of India.”

The Court further observed: “A citizen who wants to report commission of an offence, should not be treated like a criminal.” It noted the shocking facts of the case where the complainants were made to wait for hours and then subjected to abusive language by the police officer.

This judgment reinforces the principle that access to justice and dignified treatment at police stations are fundamental rights under Article 21 of the Constitution. It serves as an important reminder to law enforcement officials about their duty to respect citizens’ rights while performing their functions.

Petitioner Name: Pavul Yesu Dhasan.
Respondent Name: The Registrar, State Human Rights Commission of Tamil Nadu & Ors..
Judgment By: Justice Abhay S. Oka, Justice Ujjal Bhuyan.
Place Of Incident: Srivilliputhur, Tamil Nadu.
Judgment Date: 30-04-2025.
Result: dismissed.

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