Unnatural death in custody, including suicide, attracts strict State liability requiring compensation under Article 21.

The petitioner sought compensation for the custodial death of his 19-year-old son, Deepak, who died on 16.01.2018 while in the custody of Police Station Karawal Nagar

The deceased was arrested on 15.01.2018; the petitioner alleged that both he and his son were subjected to physical assault and extortion demands by police officials

The following morning, the petitioner was informed his son had committed suicide

A post-mortem opined the cause of death as "asphyxia due to ante-mortem hanging"

A departmental enquiry subsequently established negligence on the part of the police officers for failing to properly monitor the deceased and for the presence of unauthorized items (blades and a stole) in the lock-up

The respondents argued that compensation is not automatic and should be limited to the statutory Delhi Victim Compensation Scheme, 2018

1. Whether an unnatural death in custody, including suicide, attracts strict liability for the State to pay compensation under Article 21 of the Constitution

2. Whether the quantum of compensation for custodial death should be determined by the statutory Victim Compensation Scheme or by the "multiplier principle" derived from motor accident jurisprudence

The court applied the principle of strict liability for the protection of fundamental rights under Article 21 of the Constitution, as established in Nilabati Behera v. State of Orissa, which held that the State has a non-delegable duty of care toward persons in custody

It relied on In re: Inhuman Conditions in 1382 Prisons to classify suicide in custody as an "unnatural death"

Regarding the calculation of damages, the court followed the Division Bench ruling in Kiran v. State, which borrowed the "no-fault liability" norms and the "multiplier principle" from the Motor Vehicles Act to assess custodial death claims

further guided by the standardization of the multiplier method in Sarla Verma v. DTC and National Insurance Co. Ltd. v. Pranay Sethi

The court reasoned that when a person is deprived of liberty, the State assumes a heightened and "absolute" duty to protect their life; any unnatural death—even suicide—reflects a systemic failure of this duty

The court rejected the State's defense that compensation is tied only to the Delhi Victim Compensation Scheme, noting that the remedy in public law for the violation of Article 21 is distinct from, and in addition to, statutory schemes

Applying the facts, the court noted that the deceased was only 19 years old and that police negligence was already prima facie established via departmental proceedings

To ensure a "genuine attempt... to restore the dignity of the being," the court adopted the multiplier approach to provide a realistic recompense rather than a "token" sum under the statutory scheme

It answered that the multiplier principle is the appropriate yardstick for calculation

Based on a monthly income of ₹12,000, 40% future prospects, a 50% deduction for personal expenses, and a multiplier of 18, the court calculated the loss of dependency at ₹18,14,400

After adding ₹30,000 for conventional heads (funeral expenses and loss of estate), the court ordered the respondents to pay a total compensation of ₹18,44,400 to the petitioner within eight weeks