Sathankulam Custodial Death Case Verdict: Death Penalty & ‘Rarest of Rare’ Doctrine Explained

In a landmark verdict in one of India’s most shocking cases of police brutality, Sathankulam father-son duo custodial deaths case, the Sessions Court in Madurai has awarded death sentences to nine police personnel.

Background of the Case

• Custodial Arrest: Jayaraj and his son Benicks were detained by police in Tamil Nadu during the COVID-19 lockdown for alleged violation of lockdown restrictions.
• Alleged Police Brutality: Both were subjected to severe custodial torture inside the police station, leading to critical injuries and death of both.
• Evidence Manipulation: Police allegedly fabricated charges, destroyed evidence, and obtained remand despite visible injuries.
• Legal Action: The incident triggered nationwide protests, leading to High Court intervention and transfer of the case to the CBI.

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The Judgement of the Sessions Court

• Conviction: The court found the accused guilty of double murder, criminal conspiracy, and destruction of evidence.
• CBI Findings: The judgment relied on CBI investigation and evidence, which established custodial torture and deliberate wrongdoing.
• Rarest of Rare: The court treated the custodial torture and murder as a “rarest of rare” case due to extreme brutality and abuse of authority by police, justifying the death penalty
• Stand Against Custodial Violence: The verdict sends a clear message of zero tolerance towards police brutality and misuse of authority.
• Rule of Law: It upholds accountability of state officials and protection of fundamental rights under Article 21.

Issue of Custodial Violence in India

• Custodial Deaths: Custodial violence remains widespread, with frequent reports of deaths and torture in police and judicial custody.
• Structural Causes: Custodial violence is driven by colonial policing culture, political pressure, lack of training, and demand for quick results.
• Abuse of Power: It reflects misuse of authority by law enforcement, often to extract confessions or punish individuals unlawfully.
• Weak Accountability: Despite multiple custodial deaths, there were zero convictions (2018–22), reflecting poor accountability mechanisms.
• Institutional Failures: Magistrates, doctors, and oversight bodies often show passive or inadequate roles, weakening safeguards against torture.
• Implementation Gaps in Safeguards: Despite guidelines like D.K. Basu vs State of West Bengal, poor enforcement of arrest procedures and monitoring persists.

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Way Forward

• Enact Anti-Torture Law: India should enact a dedicated law against torture and ratify the UN Convention against Torture (UNCAT) to strengthen legal safeguards.
  • India signed the UN Convention against Torture (UNCAT) in 1997 but has not ratified it
• Strengthen Accountability Mechanisms: Establish independent police complaints authorities and ensure strict action against erring officials to improve accountability.
• Police Reforms: Promote human rights training and evidence-based interrogation methods to replace coercive practices.
  • In Prakash Singh case, SC laid down seven directives for police reforms to ensure accountability, professionalism, and reduce misuse of power.
• Procedural Safeguards: Enforce DK Basu guidelines, CCTV surveillance in police stations, and proper medical examination to prevent custodial abuse.
• Criminal Justice System Reforms: Reduce delays and improve efficiency to discourage shortcuts like torture for quick results.

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