On 20 February 2026, a Division Bench of the Allahabad High Court (Justice Shekhar B. Saraf and Justice Manjive Shukla) delivered a landmark ruling holding the State “absolutely liable” for the unnatural custodial death of a prisoner who died by suicide while in prison custody, and directed compensation of ₹10 lakh to the deceased’s legal heirs. The bench also directed the formulation of guidelines for fixing compensation in custodial death cases.
This principle is crucial because it places a non-delegable duty on the State as the custodian of life to protect all persons in custody, regardless of their guilt, age, or status. The judgment rejects the State’s attempt to treat suicide as an event beyond its responsibility, noting that custodial conditions and supervision directly impact detainees’ safety
The case arose when a minor undertrial, lodged in Pilibhit District Jail, took his own life in custody in February 2024. Though a judicial inquest and post-mortem identified the cause as suicide, the Court rejected the simplistic view that suicide absolves the State of liability. Citing settled constitutional precedents including the idea that fundamental rights do not evaporate the moment a person enters custody the Court held that custodial deaths (even if by suicide) strike at human dignity and the rule of law. It emphasized that when the State assumes custody of a person, it also assumes responsibility for their safety.
The High Court awarded ₹10 lakh significantly higher than the NHRC’s ₹3 lakh recommendation recognizing the gravity of the violation and need for meaningful redress.
To standardize compensation awards, the Bench further directed the State to draft guidelines possibly employing multiplier methods similar to those in Motor Vehicles Act compensation fixations (considering age, income, dependents). Such structured norms could ensure fairness and predictability in custodial death awards and avoid ad hoc decision-making.
The Court rejected the argument that suicide is an independent voluntary act breaking the chain of causation. It observed that a person in custody is under the complete dominion and supervision of the State. Surveillance, mental health assessment, segregation protocols, and preventive measures are all part of the State’s custodial obligations.
Thus, the Court effectively applied a standard akin to strict or absolute liability in constitutional adjudication: once death occurs in custody under unnatural circumstances, the burden shifts decisively toward the State.
This approach aligns with the principle that the State cannot evade responsibility by characterizing the death as self-inflicted when the environment of confinement itself may have contributed to vulnerability.
The Court relied on established constitutional tort jurisprudence, particularly: Rudal Sah v. State of Bihar which recognised monetary compensation as an enforceable public law remedy for unlawful detention and Nilabati Behera v. State of Orissa which unequivocally held that sovereign immunity does not apply to violations of fundamental rights in custodial death cases.
Drawing from these precedents, the High Court reiterated that public law compensation is distinct from private tort remedies. It is not contingent upon proof of individual fault in the conventional sense. Instead, it flows from the breach of a fundamental right by the State or its instrumentalities.
More importantly, the Court directed the State to frame uniform guidelines for quantifying compensation, possibly drawing from multiplier methods used in motor accident claims.
This direction is jurisprudentially significant because compensation in custodial death cases has historically been inconsistent. By encouraging structured norms, the Court aims to: Reduce arbitrariness, Ensure parity across cases and Avoid prolonged litigation for grieving families.
The Allahabad High Court’s ruling affirms a foundational constitutional principle: the State cannot disclaim responsibility for life once it has assumed custody of the person. By categorising custodial suicide as an unnatural death attracting absolute liability, the Court has clarified doctrinal ambiguities and reinforced Article 21’s protective ambit.
In a legal landscape where custodial deaths continue to test the credibility of the criminal justice system, this judgment serves as a reminder that constitutional guarantees do not end at prison gates. They begin there with heightened intensity.
