The untimely demise of Bollywood star Sushant Singh Rajput (SSR) on June 14, 2020, triggered massive media attention and convoluted legal matters. Starting as a police investigation into an alleged suicide, the case soon assumed the form of a jurisdictional and political battle between two states—Maharashtra and Bihar—joined by central agencies of investigation later. The case reached the Supreme Court when Rhea Chakraborty, the victim’s live-in partner, moved a transfer petition seeking the transfer of the case from Patna (Bihar) to Mumbai (Maharashtra). The Supreme Court judgment in the case settled the limits of criminal investigation, inter-state jurisdiction, and the role of the Central Bureau of Investigation (CBI) in highly sensitive cases.
Facts of the case:
Sushant Singh Rajput was discovered lifeless in his Mumbai residence under suspicious conditions. The Mumbai Police launched a Section 174 CrPC investigation (suspicious death). In the meantime, on 25 July 2020, the father of the victim filed an FIR in Patna, accusing Rhea Chakraborty and others of abetment of suicide, criminal breach of trust, and misappropriation of funds. The Bihar Police launched their investigation and referred the case to the CBI.
Later, Rhea Chakraborty had also submitted a writ petition in the Supreme Court under Article 32 for shifting the investigation to Mumbai, alleging that the Patna Police could not exercise jurisdiction. The real question was whether the FIR that had been filed in Patna and the CBI investigation based on it were valid and legal.
Concerns raised:
- Was the First Information Report filed by the Bihar Police within their legal jurisdiction because the accident had taken place in Mumbai?
- Whether the investigation be handed over to Mumbai Police, who were already investigating under Section 174 CrPC?
- The rationale behind the Central Government’s action to hand over the investigation to the CBI without the consent of the Maharashtra government is questionable.
Arguments:
From the Appellant (Rhea Chakraborty’s side):
The Patna Police had no right to have an FIR registered because the crime was committed in Mumbai.
The Bihar Police’s move and call for a CBI probe was politically motivated and contrary to the spirit of federalism.
The Mumbai Police inquiry should not have been interrupted and left to complete its investigation, and concurrent investigations by other agencies caused confusion.
The matter should have been shifted to Mumbai to allow for an even and impartial inquiry.
From the Respondent (State of Bihar and others):
The FIR at Patna was warranted insofar as part of the suspected offence, i.e., financial misappropriation and criminal conspiracy, could have had implications outside Mumbai.
The Mumbai Police was carrying out only an investigation, not an inquiry, and had not filed an FIR even after weeks.
The state government of Bihar was entitled to recommend a probe by the Central Bureau of Investigation under Section 6 of the Delhi Special Police Establishment Act, and the central government’s agreeing to the recommendation was legal.
Rationale:
The Court held that Bihar Police had the jurisdiction to file the FIR. It held that offences under Section 179 of the CrPC, which involve part of the act taking place, or effects arising in some other jurisdiction, permit cross-jurisdictional FIRs. Facts narrated in Sushant’s father’s FIR were that the wrongful acts had their effects in Bihar too.
Significantly, the Court held that the State of Maharashtra’s assent was not required, given that the investigation had previously been handed over to the CBI with the proper assent of Bihar prior to the filing of the transfer petition. Given that the investigation was taken over by the CBI, the Supreme Court directed the assistance of all other state agencies and proceeded to transfer the entire case to the CBI.
The Court reiterated that the truth has to be unravelled through a qualified, impartial, and independent investigation without interference from the state level.
Defects in law:
The absence of concrete legislation on inter-state investigation that spans jurisdictions creates confusion and political tensions.
The CrPC does not finally settle jurisdictional conflicts over cases involving celebrity deaths or simultaneous investigations due to public pressure.
The Delhi Special Police Establishment Act, 1946, empowering the CBI, raises in doubt the process where one state agrees but the other is the situs of the crime. The case revealed the absence of procedural restraints against media intrusion, which affected the investigative climate but is still legally unregulated.
Inference:
Rhea Chakraborty v. State of Bihar is a milestone judgment which reasserted the constitutional principle that no state can protect itself from examination if there exists a reasonable allegation and evidence requiring an independent probe. It clarified jurisdictional provisions of the CrPC, vindicated the actions of Bihar, and defined the authority of the central government for the transfer of a case to the CBI in the public interest.
Aside from its legal significance, the case displays the convergence of law, media, and public opinion, and the role of the Supreme Court in dispensing justice in the face of political and social unrest. The SSR death case decision will be a significant precedent regarding criminal procedure, jurisdictional interpretation, and federal assistance in criminal investigations.
AUTHOR DETAILS : Tanisha Mishra , Gujarat National Law University, Silvassa Campus