Karnataka High Court Directs State To File Report On Police Investigations In Dharmasthala 'Mass Burial' Cases

The Karnataka High Court has instructed the state government to file a detailed statement on the investigative steps taken by police officers in multiple unnatural deaths related to the Dharmasthala 'Mass Burial' controversy.

Today, the counsel appearing for the petitioners submitted before the Division Bench of Chief Justice Vibhu Bakhru and Justice C.M. Poonacha that there have been 74 unnatural deaths, and the police have not followed the inquest proceedings and post-mortem as per Section 174(3) of CrPC.

The counsel for the State admitted that the records regarding unnatural deaths in the Dharmasthala till 2010 have been destroyed by the police in pursuance of a government circular, as a form of administrative procedure. Post 2010, the authorities possess details about the unnatural deaths registered in Dharmasthala, the counsel submitted. The State also raised concerns about the PIL being filed after nearly 20 years.

“…When dead bodies were found, investigations had to be carried out. If a 20-year-old dies due to a fatal wound, it's an unnatural death… if it was not a disease”, the court orally remarked.

“…There are no documents for the year 2002, Your Lordship. We will trace the available records. In 2023, we have destroyed old records for administrative reasons…”, the counsel for the respondent state submitted, adding that it may not be visible as to what investigations have been carried out in cases till 2010.

To recap, the case arises out of registration of an FIR based on the complaint of a sanitation worker, who claimed that he was instructed to bury the bodies of women and children between 1995 and 2014 in the temple town of Dharmasthala.

Today, the State also contended that it had virtually looked to recover the body remains, but nothing substantial has come out of it.

SIT had taken over the probe regarding the alleged mass burial sites in July 2025.

The plea before the High Court seeks to issue a writ of mandamus directing the respondent special investigation team (SIT) to register 74 separate first information reports, one for each case documented in the petitioner's representation dated October 11, 2025.

The court, accordingly, asked the state to submit a statement on material facts about the investigations conducted by the police in multiple deaths/disappearances. The court has posted the matter to 9^th July.

Reliefs Sought In PIL

The PIL states that the burial sites must be located, human remains exhumed, and each victim should be identified through DNA matching. The plea also submits that the actual cause of death must be determined through forensic pathology.

The writ filed by Kusumavathi, mother of one of the alleged victims named Sowjanya, a teenage girl, also called for the SIT to identify the witnesses and take action against public officials who flouted the mandatory procedures while registering Unnatural Death Reports (UDRs).

One of the prayers in the writ also requires a direction to the SIT to periodically (each month) file a status report before the High Court about the ongoing investigation.

Earlier, the High Court had orally observed in a connected matter that excavation of human remains will lead to opening a Pandora's box where more people can come to court with claims of seeing bodies and seek investigation.

Case Title: Smt. Kusumavathy v. The Special Investigation Team & Anr.

Case No: WP 33799/2025