Karnataka HC orders inquiry after police failed to act when missing girl appeared at station and disclosed she had left home

The petitioner sought a writ of habeas corpus for her 19-year-old daughter, who went missing on 31 January 2026 along with another student, a minor.

An FIR was registered, and police filed successive status reports describing searches and circulation of the girls’ details.

The petitioner’s daughter was traced in Kanakapura and produced before the Court on 9 September 2026; the other girl was produced on 15 September 2026.

A further report disclosed that the petitioner’s daughter had attended Kodihalli Police Station on 12 July 2026 and stated that she had left home to marry, while the other girl had been at Malemahadeshwara Hills.

The Court found that neither girl had been identified or appropriately acted upon by police despite the circulation of their details.

Whether the police investigation into the disappearance of the petitioner’s daughter and the other girl was adequate and compliant with the applicable directions for missing-person cases.

Whether an inquiry and further corrective action were warranted in light of the police’s failure to identify or act on the girls’ whereabouts.

In exercising its jurisdiction under Article 226 of the Constitution, the Court applied the Supreme Court’s directions in Hori Lal v. Commissioner of Police, Delhi, 2002 SCC OnLine SC 37, including prompt publicity, inquiries at the missing person’s home, school and workplace, and investigation of relevant clues.

It also relied on Bachpan Bachao Andolan v. Union of India, W.P. (C) No. 75 of 2012, which requires an FIR and immediate follow-up investigation in missing-child cases and an initial presumption of abduction or trafficking unless investigation establishes otherwise.

Pinki v. State of Uttar Pradesh, (2025) 7 SCC 314, which reiterated those requirements and cautioned against official laxity.

Ramakrishna v. Director General of Police, WPHC No. 100012 of 2024 (order dated 12 September 2025), which reviewed Karnataka’s missing-person procedures and called for disciplinary accountability for officers who fail to comply.

Although police had circulated the girls’ details and conducted searches, the record showed that one girl was moving freely at Malemahadeshwara Hills and that the petitioner’s daughter had appeared at Kodihalli Police Station and disclosed that she had left home to marry.

Despite the available notices and information, the police did not identify the girls or take appropriate steps in accordance with law.

The Court considered this a serious investigative failure, particularly because one missing girl was a minor, and found that the daughters were ultimately traced only after the petitioner’s daughter’s Aadhaar details were located with the assistance of UIDAI.

The circumstances warranted an inquiry by the D.G. and I.G. of Police and corrective action.

It directed respondent No. 1 to ensure an appropriate inquiry by the D.G. and I.G. of Police into the jurisdictional police’s failures, to take action in accordance with law against officers found responsible, and to file the inquiry and investigation report before the Registry within four months.