Delhi High Court Transfers 2017 Death Case to CBI: Strong Remarks on Delhi Police’s “Myopic” Probe

The Delhi High Court has delivered a significant ruling in a 2017 unnatural-death case involving a 23-year-old hotel manager, Arnav Duggal. The court sharply criticised the Delhi Police for a “lackadaisical” and “myopic” investigation and transferred the matter to the Central Bureau of Investigation (CBI).

This article explains the facts, court’s findings, statutory basis, constitutional principles, and judicial precedents relevant to this case.

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Background of the Case

Death of Arnav Duggal in 2017

Arnav Duggal, aged 23, employed as a manager at a luxury hotel, was found dead in a flat in 2017. The only person present at the time of his death was a woman with whom he was allegedly in a relationship.

The Delhi Police, from the very beginning, treated the death as suicide.

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Petition Filed by the Mother

Allegation of Faulty Investigation

Arnav’s mother approached the Delhi High Court seeking transfer of the investigation from Delhi Police to the CBI.

She argued:

• The police presumed the death was a suicide without proper inquiry.

• The assumption was based entirely on the statement of the woman present at the scene.

• No police officer witnessed Arnav’s body hanging from the ceiling fan.

• The investigation ignored the possibility of murder.

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Police’s Stand Before the Court

Delhi Police Defends Its Investigation

The police argued that:

• Medical and oral evidence indicated death by suicide.

• There was “no room” for doubt or suspicion warranting a murder probe.

• The case had already been investigated three times by different teams:

  • Local police

  • Crime Branch

  • Special Investigation Team (SIT)

According to the police, these multiple layers ensured the probe was “insulated” from external influence and was not negligent.

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Court’s Findings on Investigative Deficiencies

Failure to Establish Motive or Reason for Suicide

Justice Tushar Rao Gedela observed that even if hanging was the cause of death, the police failed to explain:

• Why Arnav would have taken his own life

• Whether there was any psychological, emotional, or circumstantial trigger

• Whether any evidence suggested suicidal tendencies or depression

The court emphasised that the prosecution did not place on record any material explaining the alleged suicide.

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Ignored Possibility of Abetment

The Court highlighted that the investigating agencies failed to examine:

• Whether any circumstances suggested abetment (Section 306 IPC)

• Whether any conduct by people around Arnav contributed to the incident

The bench noted that the investigation was one-dimensional and narrowly focused on the suicide narrative.

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 Criticism of the Police Investigation

“Parroted” Version and Lack of Analytical Approach

The Court strongly criticised the authorities, observing that:

• All three agencies repeated the same version without deeper scrutiny

• Investigation relied heavily on the statement of the woman present

• Scientific and analytical inquiry was missing

• Key circumstances surrounding the death were ignored

• No independent evaluation of alternative possibilities was conducted

The judge described the probe as lacking bona fide, myopic, and merely adopting a pre-decided theory of suicide.

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Order for CBI Investigation

Given the serious lapses, the High Court ordered:

• Transfer of the entire case to the Central Bureau of Investigation (CBI)

• A separate inquiry into lapses committed by Delhi Police officials

The court directed the CBI to conduct both the investigation and oversight inquiry.

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Statutory Provisions Relevant to the Case

Indian Penal Code (IPC)

• Section 302: Murder (relevant because the possibility of homicide was ignored)

• Section 306: Abetment of suicide (court noted failure to examine abetment)

• Section 174 CrPC: Police inquests in cases of unnatural death

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Code of Criminal Procedure (CrPC)

• Section 156(1): Police duty to investigate cognizable offences

• Section 173(2): Mandatory filing of a complete and proper police report

• Section 482: High Court powers to intervene to ensure proper investigation

• Section 190: Magistrate’s power to ensure fairness in investigation

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Constitutional Provisions Involved

• Article 21 – Right to life includes the right to fair investigation

• Article 226 – High Court’s power to order CBI probes

• Article 14 – Ensures fairness and non-arbitrariness in investigations

A faulty, biased, or incomplete investigation directly violates Article 21.

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Judicial Precedents Supporting Court’s View

Cases Where Courts Ordered CBI Probe due to Faulty Police Investigation

1. CBI v. Rajesh Gandhi (1997)
   Courts can order CBI investigation in exceptional cases involving public confidence.

2. State of West Bengal v. Committee for Protection of Democratic Rights (2010)
   Article 226 empowers High Courts to direct CBI investigations even without state consent.

3. Vineet Narain v. Union of India (1997)
   Courts can intervene to ensure independent, fair, and effective investigations.

4. Lalita Kumari v. Government of Uttar Pradesh (2013)
   Fair, unbiased investigation is integral to Article 21.

5. Babubhai v. State of Gujarat (2010)
   When investigation appears biased or predetermined, courts must intervene.

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Conclusion

The Delhi High Court’s decision reflects the judiciary’s commitment to ensuring fair and impartial criminal investigations. The ruling highlights fundamental investigative failings in the Delhi Police’s approach, including reliance on a single narrative, lack of scientific analysis, and absence of motive assessment.

By transferring the matter to the CBI and ordering an inquiry into police lapses, the court has reiterated that investigations must be thorough, unbiased, and conducted with full adherence to legal and constitutional duties.

This case stands as a reminder that every unexplained or suspicious death must be investigated with seriousness, transparency, and fairness, especially when allegations of negligence or complicity arise.

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