'74 Unnatural Deaths, Bodies Buried Without Following Procedure': Karnataka High Court Told In PIL To Inspect Dharmasthala 'Mass Burial' Sites

Sebin James

21 July 2026 3:05 PM IST

  • 74 Unnatural Deaths, Bodies Buried Without Following Procedure: Karnataka High Court Told In PIL To Inspect Dharmasthala Mass Burial Sites
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    The mother of the girl who was allegedly raped and murdered in the temple town of Dharmasthala, told the Karnataka High Court on Tuesday (July 21) that there was 'a deeply disturbing pattern of unnatural deaths and disappearances' in and around the region.

    A Division Bench of the Chief Justice and Justice K.S. Hemalekha was hearing the PIL filed by the mother seeking a relief that the burial sites must be located, human remains exhumed, and each victim should be identified through DNA matching, and the actual cause of deaths must be determined through forensic pathology, among other reliefs.

    The plea seeks SIT to identify the witnesses and take action against public officials who flouted the mandatory procedures while registering Unnatural Death Reports (UDRs).

    Appearing for the mother, advocate Vrindra Grover submitted that several bodies were allegedly buried without following mandatory legal procedures under Section 174 of the Code of Criminal Procedure (CrPC) and the Karnataka (Investigation of Unnatural Deaths and Conduct of Inquests) Rules, 2004.

    Grover submitted that there were 74 cases of unnatural deaths tabulated by the petitioner.

    “They [dead bodies] are buried immediately on the same date and some on the very next date. The location of the grave is not recorded… Victims are uniformly tabulated as unknown persons, without their age group and gender. If I am staying in a guest house, it will record my name, address and age, and government registered ID. Even those bodies found in guest houses and lodges are buried as unknown persons…. They are recorded as suicide, not even whether it's hanging or suicide. Not even UDR numbers have been given by the police in 3 cases…,” Grover submitted before the court.

    Grover submitted that there were repeated violations of procedure contemplated under Section 174 CrPC, which requires police to report on any unnatural death including suicides, and Karnataka Unnatural Death and Conduct of Investigation Rules, 2004, which details the timeline and manner in which investigations into unnatural deaths must be conducted.

    The petitioner also pointed out the constitution of SIT by the state on July 19, 2025, to look into these matters. The counsel read from the notification constituting SIT to emphasise the duties vested on SIT.

    “…The SIT constituted therein is declared as police station and officer of senior rank is declared as SHO. The SIT constituted on 19 July has power to conduct proceedings under BNS and submit final report”, the counsel said, referring to the report.

    The notification mandates that the State shall periodically report the progress, must comprehensively investigate cases registered in relation to the controversy and all other cases registered in other police stations related thereto, the counsel added further.

    Grover also drew the court's attention to five specific cases to illustrate the pattern of cases in Dharmasthala. The petitioner pointed out the instance of an unidentified woman who was found dead in a lodge. The morning after the death, police wrote to the town panchayat and registered it as murder, the counsel told the court. The body was cremated soon thereafter, the counsel added.

    “...Even if the body is unclaimed on a roadside, the police can't take it and dispose it off. Where is the inquest, post-mortem, and procedure under Section 174 CrPC and rules regarding Unnatural Deaths?”, the counsel questioned the state further.

    In another instance, the UDR (Unnatural Death Report) was 'erased from the record altogether', the counsel added. In yet another instance, a young woman aged 25-30 was found hanging in a forest nearby which too was declared a suicide, the counsel added.

    “…But was she hanged after homicide? We will never know because on the very next day the body is buried, no inquest is done”, the counsel informed the court.

    There was even a 35-year-old man who was found dead in a guest house run by Dharmasthala Trust, the counsel contended.

    “…No effort was made to find out who the person is”, Grover said.

    Meanwhile the State sought time since the Advocate General was held up in another court and he was to be assisted by the State Public Prosecutor in the matter.

    The bench posted the matter for further hearing on August 24.

    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.

    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.

    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

    Sebin James

    Sebin James

    Sebin James is a Correspondent with LiveLaw, covering the Karnataka High Court

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