CW-2021-0002Dhenkanal, OdishaJudgment 27 January 2021

Dhenkanal Man and Another vs State Of Odisha & Others

A Dhenkanal man was found writhing in pain inside a Dhenkanal liquor shop and brought into Dhenkanal Town Police Station at 3:20 AM on 7 June 2005. Despite his visibly precarious physical state, police left him unattended on the police station verandah for six hours without arranging medical treatment, and he subsequently succumbed to ante-mortem cranio-cerebral injuries. The Division Bench of the Orissa High Court held that regardless of whether police caused the initial injuries, keeping an injured arrestee in custody for six hours without medical attention constituted gross and fatal negligence attracting strict liability for custodial death under Article 21. The Court directed the State of Odisha to pay Rs. 5,00,000 compensation to the deceased parents. Matters not addressed in the cited judgment text are not recorded here.

Externally reportedV2
What this record means

This page documents a court-adjudicated case from the judgment and cited sources below. Findings are attributed to the court; this record does not add findings of its own.

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Report card

By judgment dated 27 January 2021 in W.P.(C) No. 13774 of 2005, the Orissa High Court (Coram: S. Muralidhar, Biswajit Mohanty, JJ.) returned findings adverse to 2 police personnel, namely: Inspector-in-Charge, Dhenkanal Town Police Station; Sub-Inspector, Dhenkanal Town Police Station, and directed payment of compensation of Rs 5 lakh (Rs 5,00,000).

Register number
OD 06 CW 0001
Case reference
W.P.(C) No. 13774 of 2005 / 2021 LiveLaw (Ori) 13
Court and date
Orissa High Court (Coram: S. Muralidhar, Biswajit Mohanty, JJ.), 27 January 2021
Officer(s) at the material time
Inspector-in-Charge, Dhenkanal Town Police Station; Sub-Inspector, Dhenkanal Town Police Station
Present service status
Not ascertained from the cited sources.
Provisions invoked
Article 21 of the Constitution of India; Article 226 of the Constitution of India; Article 227 of the Constitution of India
Finding of the Court (extract)
“Even if it is not established that the ante mortem injuries found on his person during post-mortem were caused by the Police, the law of strict liability for the negligence of the police in not meeting the basic minimum standard …” (at para 29)
Verdict, sentence and quantum
Adverse finding + compensation. Sentence: compensation only. Compensation: Rs 5 lakh (Rs 5,00,000).
Present status of the proceedings
No further proceedings are recorded in the cited sources; the judgment is the concluded position shown.

Compiled from the judgment and the cited sources. Findings are those of the court; this card adds none of its own.

The Orissa High Court judgment dated 27 January 2021 is the concluded position shown in the cited sources.

Recorded allegations

1
Custodial deathPrimary
Material fact supported

Reliable material supports a specifically documented fact relevant to that allegation, not necessarily the full allegation, causation, intent, unlawfulness, or responsibility.

Official finding: supports allegation.

What the court found

Holding not recorded separately.

“Even if it is not established that the ante mortem injuries found on his person during post-mortem were caused by the Police, the law of strict liability for the negligence of the police in not meeting the basic minimum standard …” (para 29)

Institutional response

1
27 Jan 2021

Order issued

Concluded
Orissa High Court External · Binding

The Orissa High Court recorded adverse findings against police personnel and ordered Rs 500,000.

Compensation ordered · Supports allegation (for the compensated wrong only).
Source: 2021 LiveLaw (Ori) 13
Not yet re-checked.

Follow-up history

1
19 Sep 2026

(Round-8 full re-verification: published record re-checked against the judgment text (outcome, officers, quote, key facts) plus methodology-compliance pass; skills-guided adversarial re-verification of the published record against the judgment text (reverify/t1-*/adversarial-8.jsonl))

Corrections (0): No corrections recorded.

Review: Solo Staff combined review (one combined attestation) — not yet recorded.

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