The Delhi High Court has directed the Delhi government to pay ₹18.44 lakh as compensation to the father of a 19-year-old who died an unnatural death while in police custody at Karawal Nagar Police Station, holding that the State cannot evade liability even if the custodial death is alleged to be a suicide.

Justice Sachin Datta observed that persons in State custody continue to enjoy the protection of Article 21 of the Constitution, and that any unnatural death in custody reflects a failure of the authorities entrusted with their care.

"An unnatural death in custody, even if by suicide, is not a private act divorced from State responsibility, but reflects an omission of duty on the part of those charged with safekeeping. The State cannot escape responsibility by invoking statutory schemes or by contending absence of direct culpability. The very fact of custodial death, being unnatural, attracts liability and obliges the Court to mould relief in the form of compensation," the Court observed.

The Court further stressed that custodial deaths raise issues that go beyond the individual case and strike at the heart of the rule of law.

"Custodial death is not merely an individual tragedy but a matter of systemic concern, striking at the very foundation of the rule of law. When a person is deprived of liberty and placed in the custody of the State, the authorities assume a heightened duty of care. Any lapse resulting in death within custody, whether attributed to violence, negligence, unexplained circumstances or even suicide, demands judicial scrutiny, for it implicates both the dignity of the individual and the credibility of the justice system," the judgment stated.

The case arose from a petition filed by Shyam Sunder, who sought compensation for the death of his adopted son, Deepak, while in police custody in January 2018.

According to the petition, Deepak was taken into custody on January 15, 2018, in connection with an FIR and was detained at the Karawal Nagar Police Station. Sunder alleged that when he visited the police station to meet his son, he too was detained for several hours before being released. He further claimed that both he and his son were assaulted by police personnel and that officials demanded money for Deepak's release.

The following day, Deepak was taken to Guru Tegh Bahadur Hospital, where he was declared brought dead. Sunder was informed that his son had allegedly died by suicide. The post-mortem report recorded the cause of death as asphyxia due to ante-mortem hanging.

Before the High Court, Sunder argued that the State was liable to compensate him since his son suffered an unnatural death while in police custody.

The Delhi government opposed the plea, contending that compensation does not automatically follow every custodial death.

Rejecting the government's argument, the Court held that an unnatural custodial death gives rise to public law liability, and that the State, as the custodian of life and liberty, is constitutionally obligated to compensate the deceased's family for the violation of the right to life under Article 21.

For determining the compensation, the Court applied the multiplier method. It assessed the deceased's monthly income at ₹12,000, added 40 per cent towards future prospects, and applied a multiplier of 18. After including conventional amounts towards funeral expenses and loss of estate, the Court arrived at a compensation of ₹18.44 lakh.

The Delhi government has been directed to pay the compensation to the petitioner within eight weeks.

Senior Advocate Trideep Pais, along with advocates Sanya Kumar, Chiranjeev Singh Marwaha, Saloni Ambastha, Sakshi Jain and S Abinaya, appeared for the petitioner. CGSC Premtosh K Mishra, assisted by advocates Shrey Sharma, Anubhav Upadhyay and Arpit Bansal, represented the respondents.