The Chhattisgarh High Court dismissed a petition that sought a fresh, independent probe into an encounter in Narayanpur district that left two senior Maoist cadres dead. The petition, filed by Raja Chandra who said one of the deceased was his father, Katta Ramchandra Reddy asked the court to direct constitution of an external Special Investigation Team and to award compensation to the family alleging the deaths were a staged, custodial execution. A division bench led by Chief Justice Ramesh Sinha and Justice Bibhu Datta Guru found no material on record to support the petitioner’s claim and concluded the state had followed investigation protocols and statutory safeguards.
The petitioner’s case, argued by Senior Advocate Colin Gonsalves, rested on two linked contentions. First, that the timing and circumstances of the encounter on September 22, 2025, after a flurry of political statements from Maoist spokespeople made it likely the men were first detained and then killed, rather than killed in a genuine gunfight. Second, that forensic and postmortem records showed wounds inconsistent with a battlefield death and suggested torture. The petitioner asked the court to preserve and examine postmortem videography and ballistic evidence, to register a formal FIR into the allegation of murder, and to send the matter to an out-of-state SIT so the probe would be impartial.
The state answered in detail, supplying a timeline of actions taken after the encounter and emphasising that the deaths occurred during an anti-naxal operation based on intelligence. According to the return, the police recovered weapons and explosives at the scene, forwarded preliminary and detailed reports to the National Human Rights Commission, arranged videographed postmortems, conducted inquests before an executive magistrate, and sent seized weapons for ballistic testing. A zero FIR was recorded locally and a formal FIR was registered at the Orchha police station. Forensic tests reported firing discharge residue on the hands of the deceased and indicated weapons were in active condition and had been fired. The return also listed numerous criminal cases and antecedents attributed to one of the deceased, which the state said corroborated its account of the encounter.
The court’s analysis did not dispute that procedural steps were imperfectly carried out in every respect, but it concluded the available material did not establish a constitutional case for extraordinary relief. The judges underlined that the power to order a central or out-of-state agency probe is exceptional and must be exercised sparingly, pointing to Supreme Court precedents that require clear, credible evidence of a serious miscarriage of justice before transferring investigations. The High Court noted that isolated procedural lapses, or the presence of injuries that might plausibly invite suspicion, are not by themselves enough to overturn the state’s account when the record otherwise shows compliance with NHRC and apex court guidelines.
In dismissing the petition, the bench recorded that the petitioner’s allegations amounted largely to apprehension and speculation rather than admissible evidence. The court observed that the videography and forensic reports had been produced to the petitioner and that independent examinations, including ballistic and hand-swab analyses, had been carried out and reported to the court and the NHRC. The judges also stressed the difficulty of reconstructing events that occur in dense forest terrain during counter-insurgency operations, where injuries and conditions may be caused by the environment as well as by combat. Ultimately the petition was found to be devoid of merit and was dismissed.
The order is a compact illustration of how modern courts balance individual liberty and accountability against the operational realities of counter-insurgency. It underscores the high threshold required to displace an official account of a security operation and the judiciary’s preference for restraint before ordering extraordinary investigative measures. For families and lawyers challenging the conduct of security forces, the ruling signals that detailed, corroborative forensic evidence and precise gaps in procedure will be necessary to obtain a court-directed special probe.
Case Details: WPCR No. 521 of 2025, Raja Chandra S/o Late K.R. Chandra vs State of Chhattisgarh and Others. For the Petitioner(s): Mr. Colin Gonsalves, Senior Advocate (through Video Conferencing), assisted by Mr. Kishore Narayan and Mr. Manik Gupta, Advocates. For the Respondent(s): Mr. Prafull N. Bharat, Advocate General, assisted by Mr. Y. S. Thakur, Additional Advocate General.
