The Delhi High Court has directed the Delhi government to pay ₹18.44 lakh in compensation to the adoptive father of a 19-year-old who died by suicide while in police custody, ruling that an unnatural custodial death — even one attributed to suicide — constitutes a violation of the fundamental right to life under Article 21 of the Constitution and attracts public law liability. The judgment was delivered on Wednesday, 2 July by a single-judge Bench of Justice Sachin Datta.

Background: What Happened at Karawal Nagar Police Station

The writ petition was filed by Shyam Sundar, the adoptive father of Deepak, who was arrested in connection with an FIR and lodged at Karawal Nagar Police Station. According to the petitioner, both he and his son were allegedly assaulted by police personnel following the arrest, who also reportedly demanded ₹20,000–30,000 for securing Deepak's release.

On 16 January 2018, the day after the arrest, Shyam Sundar was informed that his son had allegedly died by suicide in custody. Deepak was declared 'brought dead' at Guru Tegh Bahadur Hospital. A post-mortem conducted by a medical board attributed the cause of death to 'asphyxia due to ante-mortem hanging'.

The Court's Ruling on State Liability

Justice Datta held that the state, as custodian of life and liberty, bears an absolute duty to protect persons in its custody and cannot escape liability merely because the death was self-inflicted. 'The very fact of custodial death, being unnatural, attracts liability and obliges the court to mould relief in the form of compensation,' the court said.

The judgment further noted that a person in custody does not forfeit fundamental rights guaranteed under Article 21, and that an unnatural death in custody — regardless of its immediate cause — reflects an omission of duty by those charged with safekeeping. 'It is not a private act divorced from state responsibility,' the court observed.

Rejection of Government's Defence

The Delhi government had opposed the petition, arguing that compensation is not an automatic consequence of every custodial death and that the matter should be governed by the statutory framework under Section 357A of the Code of Criminal Procedure and the Delhi Victim Compensation Scheme.

Justice Datta rejected this contention outright, holding that compensation for custodial deaths flows directly from the violation of Article 21 and is legally distinct from statutory remedies. The state, the court ruled, 'cannot escape responsibility by invoking statutory schemes or by contending absence of direct culpability.'

How the Compensation Was Calculated

Taking the deceased's monthly income at ₹12,000, adding 40% towards future prospects, and applying a multiplier of 18, Justice Datta arrived at a total compensation of ₹18,44,400. This figure includes conventional amounts towards funeral expenses and loss of estate.

The court directed the authorities to disburse the full amount within eight weeks and disposed of the writ petition. The judgment underscores that custodial death is 'not merely an individual tragedy but a matter of systemic concern, striking at the very foundation of the rule of law.'

Broader Implications for Custodial Accountability

This ruling adds to a growing body of jurisprudence holding the state strictly accountable for deaths in custody, irrespective of the mechanism of death. Notably, the court's reasoning — that any lapse resulting in death within custody 'demands judicial scrutiny' — sets a high evidentiary bar for state agencies seeking to distance themselves from custodial fatalities. With custodial deaths remaining a persistent concern in India, the judgment may be cited in future compensation claims where direct police violence is difficult to establish.