Legal Review and Analysis of Tamilaga Vettri Kazhagam vs P H Dinesh & Ors 2025 INSC 1224

1. Heading of the Judgment

Case Name: Tamilaga Vettri Kazhagam vs. P.H. Dinesh & Ors. (and connected petitions)
Citation: 2025 INSC 1224
Court: Supreme Court of India
Judges: Justice J.K. Maheshwari and Justice N.V. Anjaria
Date: October 13, 2025

2. Related Laws and Sections

The judgment references the following legal frameworks:

• Bharatiya Nyaya Sanhita, 2023 (BNS): The First Information Report (FIR No. 855/2025) was registered under Sections 105, 110, 125B, and 223 of the BNS.

• Tamil Nadu Public Property (Prevention of Damage and Loss) Act, 1992: The FIR was also registered under Section 3 of this state act.

• The Constitution of India: Article 32: The foundational jurisdiction under which the Writ Petitions (Crl.) Nos. 412 and 413 of 2025 were filed directly before the Supreme Court.

• Precedent Case: State of W.B. vs. Committee for Protection of Democratic Rights (2010) 3 SCC 517: This judgment was cited to outline the principles for transferring an investigation to the Central Bureau of Investigation (CBI).

3. Basic Judgment Details

• Appellants/Petitioners: A batch of petitions was clubbed together, including:
  Tamilaga Vettri Kazhagam (TVK) - the political party that organized the rally.
  Panneerselvam Pitchaimuthu - the father of a deceased victim.
  G.S. Mani and other public-spirited citizens.
  S. Prabakaran and Selvaraj P. - relatives of deceased victims filing directly under Article 32.

• Respondents: The State of Tamil Nadu, its officials, and the Union of India.

• Origin of Case: These petitions arose from various orders of the Madras High Court (both Principal Bench and Madurai Bench) concerning the investigation into the Karur stampede.

• Subject Matter: The core issue revolved around the demand for an independent and impartial investigation into the tragic stampede, with specific prayers for a CBI probe and the formulation of Standard Operating Procedures (SOPs) for public rallies.

4. Core Principle of the Judgment

The Central Issue

Whether, in the circumstances of the Karur stampede—a tragedy of significant magnitude with alleged political undertones and pre-judicial statements by state police officials—the investigation should be transferred from the State Police to the Central Bureau of Investigation (CBI) to ensure fairness, impartiality, and public confidence in the criminal justice process.

In-Depth Analysis and Reasoning of the Supreme Court

The Supreme Court, as an interim measure, allowed the petitions and transferred the investigation to the CBI. Its reasoning was structured around two primary pillars:

A. Critical Analysis of Procedural Irregularities by the High Court

The Supreme Court expressed serious concern over the manner in which the Madras High Court handled the multiple petitions related to the incident.

• Multiplicity and Forum Confusion: The Court noted that numerous petitions seeking similar relief (CBI investigation and SOP formulation) were filed before both the Principal Bench (Chennai) and the Madurai Bench of the High Court. The Karur district falls under the territorial jurisdiction of the Madurai Bench.

• Suo Motu Overreach by Single Judge: The Supreme Court strongly criticized the learned Single Judge of the Principal Bench for:
  Entertaining a writ petition (WP Crl. No. 1000 of 2025) that should have ideally been filed before the Madurai Bench.
  Expanding the scope of the petition suo motu (on its own) to order the formation of a Special Investigation Team (SIT) by the state, even though this was not prayed for in the petition.
  Doing so without joining necessary parties (like TVK) and without providing any reasoned findings to show dissatisfaction with the ongoing police investigation.

• Contradictory Orders: The Supreme Court highlighted a stark contradiction: on the same day, a Division Bench of the Madurai Bench found no flaw in the police investigation and denied a CBI probe, while the Single Judge in Chennai, without referring to any specific material, expressed dissatisfaction and ordered an SIT. This created judicial confusion and undermined the process.

B. Substantive Reasons for Transferring the Investigation to CBI

The Supreme Court applied the principles from State of W.B. vs. Committee for Protection of Democratic Rights to the facts of the case and found a compelling need for a CBI investigation.

• Exceptional Circumstances: The Court acknowledged that a CBI probe is not to be ordered routinely. However, this case presented exceptional circumstances:
  National Conscience and Ramifications: The death of 41 individuals and injuries to over 100 in a preventable stampede had a profound impact, shaking the national conscience.
  Erosion of Public Confidence: The Court took note that top officials of the Tamil Nadu Police had held press conferences to defend their subordinates and abjure fault even before the investigation was complete. This, the Court held, "prima facie, in itself creates a doubt in the minds of the general public about the independence and impartiality of the investigation."
  Political Undertones: The incident involved a political rally organized by a party in opposition to the state's ruling dispensation. An investigation by the state police machinery, which is under the control of the ruling government, would naturally be viewed with suspicion.
  Enforcement of Fundamental Rights: The Court emphasized that the victims and their families have a fundamental right to a fair and impartial investigation. Transferring the case to the CBI was deemed necessary to enforce this right and instill public trust in the justice system.

5. Final Outcome and Supreme Court's Directions

The Supreme Court allowed the petitions and issued the following interim directions:

1. Transfer of Investigation: The investigation in FIR No. 855/2025 is transferred from the Tamil Nadu Police to the Central Bureau of Investigation (CBI).

2. Handover of Evidence: The State Police, the SIT constituted by the High Court, and the One-Man Enquiry Commission are directed to immediately hand over all evidence and documents to the CBI.

3. Suspension of Parallel Probes: The operations of the SIT and the State-appointed Enquiry Commission are suspended.

4. Constitution of a Supervisory Committee: The Court constituted a three-member Supervisory Committee to be headed by Justice Ajay Rastogi (Retd.), former Judge of the Supreme Court. The Committee is empowered to:
   Monitor and supervise the CBI investigation.
   Review evidence and issue directions on the scope of the probe.
   Ensure the investigation is thorough and reaches a logical conclusion.

5. State Cooperation: The State of Tamil Nadu is directed to provide full cooperation and logistical support to the CBI and the Supervisory Committee.

6. Monthly Reports: The CBI is directed to submit monthly progress reports to the Supervisory Committee.

7. SOP Matter in High Court: The pending writ petition (WP Crl. No. 884 of 2025) regarding the formulation of SOPs for public rallies is to be assigned to a Division Bench of the Madras High Court by the Chief Justice.

6. Multiple Choice Questions Based on the Judgment

Question 1: In the case of Tamilaga Vettri Kazhagam vs. P.H. Dinesh & Ors. (2025 INSC 1224), what was the primary reason cited by the Supreme Court for transferring the Karur stampede investigation to the CBI?

A) The State Police had formally requested the transfer due to a lack of resources.
B) The CBI has a statutory mandate to investigate all cases involving death.
C) To ensure impartiality and public confidence, as pre-judicial statements by top police officials had created doubts about a fair state-led probe.
D) The political party involved, TVK, had a legal right to choose its investigating agency.

B) A three-member Supervisory Committee headed by a retired Supreme Court Judge.

Question 2: Apart from transferring the investigation to the CBI, what unique supervisory mechanism did the Supreme Court establish in this judgment?

A) A Joint Parliamentary Committee to oversee the investigation.
B) A three-member Supervisory Committee headed by a retired Supreme Court Judge.
C) Direct supervision by the Chief Justice of the Madras High Court.
D) A Special Investigation Team (SIT) composed of officers from multiple states.

B) A three-member Supervisory Committee headed by a retired Supreme Court Judge.