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CASE BRIEF.docx
Maharashtra National Law University, Aurangabad - CN-585684

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NALSAR University of Law Hyderabad on 2021-11-26 1%

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legalserviceindia.com 1%

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www.ndtv.com 1%

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Edison State College on 2024-02-21 1%

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CASE BRIEF
RHEA CHAKRBORTY VS STATE OF BIHAR
4 Case: Rhea Chakraborty vs The State Of Bihar on 19 August, 2020
Citation: AIR 2020 SUPREME COURT 3826, AIRONLINE 2020 SC 685

FACTS
5 1. This case centers on the aftermath of the tragic death of actor Sushant
Singh Rajput on June 14, 2020, in Mumbai.
1 2. Initially, the Mumbai Police initiated an inquest under Section 174 of the
CrPC to determine the cause of death, with early findings suggesting
suicide.
3. However, on July 25, 2020, Sushant’s father, K.K. Singh, lodged an FIR
in Patna, Bihar, accusing Rhea Chakraborty (Sushant’s partner) and her
family members of abetment of suicide, cheating, criminal breach of
trust, and mental harassment under Sections 306, 341, 342, 380, 406, and
420 of the IPC.
4. The FIR alleged that Rhea and her associates isolated Sushant from his
family, manipulated him emotionally, exploited his finances, and
contributed to his deteriorating mental health.
5. Responding to the FIR, the Bihar Police initiated an investigation and
sought cooperation from the Mumbai Police.
6. However, jurisdictional disputes arose when the Mumbai Police denied
the Bihar Police access to relevant evidence.
7 7. Rhea Chakraborty subsequently filed a petition in the Supreme Court,
seeking the transfer of the FIR from Bihar to Mumbai, asserting that the
events leading to the case occurred entirely within Mumbai's jurisdiction.

ISSUES RAISED
1. Jurisdictional Validity:
Whether the Bihar Police had jurisdiction to investigate an offense that
allegedly occurred in Mumbai?
2. Transfer of Investigation:

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3. Whether the case should be transferred to the Mumbai Police or the

Central Bureau of Investigation (CBI)?
4. Interference with Federal Structure:
Whether the involvement of multiple state police forces violated the
principles of cooperative federalism?

CONTENTION:
1. PETITIONER’S SIDE: Rhea Chakraborty, the petitioner in question
contended that the FIR lodged in Bihar was jurisdictionally invalid, as the
alleged incidents that formed the basis of the complaint occurred entirely
within Mumbai, thereby falling outside the investigative purview of the Bihar
Police under the territorial jurisdiction framework of the Code of Criminal
Procedure, 1973. She argued that the Mumbai Police had already
commenced an inquest under Section 174 of the CrPC, which was legally
sufficient for determining the cause of death, making a parallel investigation
redundant and procedurally untenable. Additionally, she raised concerns
2 about the adverse impact of pervasive media coverage on her fundamental
right to a fair trial, as guaranteed under Article 21 of the Constitution of India.
The overwhelming media scrutiny and politicization of the case, she argued,
created a prejudiced environment that necessitated judicial intervention to
safeguard the integrity of the legal process. Consequently, she sought the
Supreme Court's intervention to transfer the investigation to the appropriate
jurisdiction.

2. RESPONDANT’S SIDE: The State of Bihar argued that the registration

3 of the FIR in Patna was legally valid under Section 179 of the Code of Criminal
Procedure, 1973. This provision stipulates that an offense may be investigated
not only where it was committed but also where the consequences of the
offense are felt. Since the family of the deceased, Sushant Singh Rajput,
resided in Patna and claimed to have experienced the impact of the alleged
offenses there, the jurisdiction of the Bihar Police was justified. Furthermore,
the State contended that the involvement of the Bihar Police was necessitated
by the complainant’s apprehension regarding the impartiality of the
investigation conducted by the Mumbai Police. Given the complainant’s
concerns about potential bias or lack of action, the Bihar Police acted within
its rights to initiate an investigation to ensure justice and transparency in the
matter. This approach, they argued, was consistent with the principles of
fairness and due process.

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RATIONALE:
The Supreme Court delivered a landmark judgment on August 19, 2020,
addressing the complexities of the case. The key observations and rulings were
as follows:
1  i
In the present case, the Mumbai Police has attempted to stretch the purview of
Section 174 without drawing up any FIR and therefore, as it appears, no investigation
pursuant to commission of a cognizable offence is being carried out by the Mumbai
police. They are yet to register a FIR. Nor they have made a suitable determination, in
terms of Section 175(2) CrPC. Therefore, it is pre-emptive and premature to hold that
a parallel investigation is being carried out by the Mumbai Police. In case of a future
possibility of cognizance being taken by two courts in different jurisdictions, the issue
could be resolved under Section 186 CrPC and other applicable laws. No opinion is
therefore expressed on a future contingency and the issue is left open to be decided, if
needed, in accordance with law.
1  ii
The proceeding under Section 174 CrPC is limited to the inquiry carried out by the
police to find out the apparent cause of unnatural death. These are not in the nature
of investigation, undertaken after filing of FIR under Section 154 CrPC. In the instant
case, in Mumbai, no FIR has been registered as yet. The Mumbai Police has neither
considered the matter under Section 175 (2) CrPC, suspecting commission of a
cognizable offence nor proceeded for registration of FIR under Section 154 or
referred the matter under Section 157 CrPC, to the nearest magistrate having
jurisdiction.

DEFECTS OF LAW:
6  Ambiguity in Multi-State Investigations: This ambiguity is particularly
problematic in high-profile cases where media attention and public interest demand
swift action. The lack of a codified process for coordinating between states in such
matters highlights the need for legislative reforms.
 Delayed Central Intervention: The case also underscored the detrimental
impact of delayed central intervention in resolving jurisdictional conflicts. The
prolonged dispute between the Bihar and Mumbai Police regarding the authority to
investigate caused significant delays. Despite the case's high-profile nature and public
scrutiny, the Central Bureau of Investigation (CBI) was only brought into the matter
after the Supreme Court intervened.
 Media and Political Interference: The case highlighted the pervasive
influence of sensationalized media coverage and political narratives on the legal
process. Media houses engaged in speculative reporting, shaping public perception
and creating undue pressure on law enforcement agencies and judicial authorities.

INFERENCE:
This case remains a testament to the challenges of administering justice in a system
influenced by competing interests, federal complexities, and public scrutiny. By transferring

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the case to the CBI, the Supreme Court ensured that public confidence in the investigative
process was maintained.

i
https://indiankanoon.org/doc/97339536/, [Cites 42, Cited by 26]
ii
https://indiankanoon.org/doc/97339536/, (Cites 42, Cited by 26)

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