The Court rules that the State Human Rights Commission overstepped its jurisdiction in adjudicating police conduct and awarding compensation.
In a significant ruling, the Madras High Court's Madurai Bench has set aside an order by the State Human Rights Commission (SHRC) that had directed police officers to pay compensation in a case involving alleged misconduct in handling complaints. The judgment, delivered by Justices M. Dhandapani and N. Dilip Kumar, found that the SHRC acted beyond its jurisdiction by intervening in police conduct and compensation matters.
The case arose when T. Parthiban and other petitioners, who were police officers at the Arumuganeri Police Station, were accused of mishandling complaints lodged by a woman, the fourth respondent in the case. She alleged that the officers had threatened her and failed to act on a serious complaint involving an assault on her child, instead filing a case against her and her husband.
The SHRC had initially examined witnesses from both sides and concluded that the allegations were credible, ordering the officers to pay Rs. 1,00,000 each in compensation. However, the police officers challenged this order, arguing that the SHRC lacked the authority to adjudicate such matters, especially concerning the conduct of police officials and the registration of criminal cases.
In its judgment, the High Court emphasized that while the SHRC is empowered to address human rights violations, it does not have the jurisdiction to conduct inquiries into police conduct in handling complaints or to award compensation. The Court pointed to the landmark Supreme Court ruling in Lalita Kumari v. Government of Uttar Pradesh, which prescribes remedies through appropriate Magistrate Courts for grievances against police inaction or misconduct.
The High Court underscored that any grievances related to police conduct should be addressed through the appropriate legal channels, depending on the nature of the allegations. It concluded that the SHRC's order exceeded its mandate, thereby setting a crucial precedent on the limits of human rights bodies in adjudicating police matters.
The petitioners were represented by Advocate Mr. R. Anand, while the respondents included representatives from the government and the SHRC. The ruling reaffirms the separation of powers and the specific jurisdictions of human rights commissions and judicial courts in India.
Bottom Line :
The State Human Rights Commission does not have the jurisdiction to conduct an enquiry and pass an order for compensation in cases involving the manner of handling complaints by police officials, especially when the allegations relate to the registration of criminal cases or police conduct.
Statutory provision(s): The Protection of Human Rights Act, 1993; Judgments referred: Lalita Kumari v. Government of Uttar Pradesh, AIR 2014 SC 187
