Supreme Court Orders Fresh Investigation Into 2012 Dharmasthala Rape-Murder Case

The Supreme Court of India has ordered a de novo investigation into the 2012 rape and murder of a 17-year-old student in Dharmasthala, Karnataka, citing severe lapses in previous probes conducted by state and central agencies. A bench comprising Justices Sanjay Kumar and Sanjeev Sachdeva directed the Karnataka government to constitute a new Special Investigation Team (SIT) to conduct the inquiry, with a mandate to complete the process and file a report within three months.

The case involves the death of a 17-year-old college student who disappeared on October 9, 2012, while returning home in Dakshina Kannada district. Her body was discovered the following day near a bathing ghat in Mannasanka, showing signs of sexual assault and strangulation. Despite investigations by the Karnataka CID and later the CBI, the case remained unsolved. Santhosh Rao, the sole individual arrested and prosecuted for the crime, was acquitted by a CBI special court in June 2023 due to a lack of evidence.

The Supreme Court expressed shock at the quality of the earlier investigations, noting that agencies failed to secure basic forensic evidence, including the victim's personal belongings and vaginal swabs, which were not properly preserved for DNA analysis. The court further observed that the prosecution failed to establish any connection between the accused and the crime scene, and that critical leads, such as the examination of potential witnesses, were neglected.

FSL Bengaluru forensic reports documented matching soil trace evidence between the victim's clothes and vaginal swab, nail clippings, and 26 Material Objects preserved in the judicial record.

To ensure a fair and transparent process, the Supreme Court has explicitly barred any officer who participated in the previous investigations by the Belthangady Police, Karnataka CID, or CBI from serving on the new SIT. The team is to be headed by a senior state police officer and must include investigators proficient in modern forensic and investigative technology. The court emphasized that the state must provide protection to witnesses, noting that several individuals associated with the case reportedly died under mysterious circumstances in the years following the incident.

The Supreme Court clarified that while it has ordered a fresh investigation, Santhosh Rao remains protected under Article 20(2) of the Constitution and Section 300 of the CrPC, meaning he cannot be subjected to a second prosecution for the same offense. The court also stated that its observations regarding the investigative failures should not be construed as a prima facie opinion on the culpability of any specific individuals. The state is required to submit a compliance report on the SIT's progress within the three-month deadline.