Karnataka HC Hears PIL Alleging 74 Unnatural Deaths Were Buried Without Mandatory Procedure In Dharmasthala

Bengaluru, July 21, 2026: The Karnataka High Court on Tuesday heard a public interest litigation (PIL) filed by the mother of a girl who was allegedly raped and murdered in Dharmasthala, with the petitioner alleging a disturbing pattern of unnatural deaths and disappearances in and around the temple town.

The plea seeks a court-monitored investigation into alleged mass burial sites and urges authorities to locate the burial grounds, exhume human remains, identify victims through DNA matching and determine the actual causes of death through forensic examination, Live Law reported.

A Division Bench comprising the Chief Justice and Justice K.S. Hemalekha heard the matter. Appearing for the petitioner, advocate Vrinda Grover argued that several bodies had allegedly been buried without following the mandatory legal procedure under Section 174 of the Code of Criminal Procedure (CrPC) and the Karnataka (Investigation of Unnatural Deaths and Conduct of Inquests) Rules, 2004.

The plea also seeks directions to the Special Investigation Team (SIT) to identify witnesses and initiate action against public officials who allegedly failed to follow the prescribed procedure while registering Unnatural Death Reports (UDRs).

Questions Over Burials

Grover told the court that the petitioner had compiled details of 74 cases of unnatural deaths and claimed that many bodies were buried either on the same day they were recovered or the following day without proper documentation. According to the submissions, details such as the location of graves, the age and gender of victims, and even UDR numbers were missing in several cases.

The counsel argued that many victims were simply recorded as "unknown persons", even in cases where bodies were recovered from lodges and guest houses that ordinarily maintain identity records of their visitors. In some cases, deaths were recorded only as suicides without specifying the manner of death, while three cases allegedly did not mention UDR numbers at all.

Grover submitted that these were repeated violations of the procedure prescribed under Section 174 CrPC, which governs inquiries into unnatural deaths, as well as the Karnataka rules that lay down the manner and timeline for such investigations.

SIT Investigation Highlighted

The petitioner also referred to the Karnataka government's July 19, 2025, notification constituting the SIT to investigate the controversy. Reading from the notification, Grover submitted that the SIT had been declared a police station, with a senior officer designated as the Station House Officer (SHO), empowering it to conduct investigations under the Bharatiya Nyaya Sanhita (BNS) and file final reports.

According to the petitioner, the notification requires the SIT to comprehensively investigate all cases linked to the controversy, including those registered at other police stations, while periodically reporting progress to the State.

To illustrate the alleged pattern, the petitioner cited five individual cases before the court. In one case, an unidentified woman was found dead in a lodge.

Police reportedly registered the case as murder and informed the town panchayat the next morning, but the body was cremated shortly thereafter. Grover questioned how such disposal could have taken place without an inquest or post-mortem, as required under Section 174 CrPC.

The counsel also claimed that in another case, the UDR had been "erased from the record altogether". In yet another instance, a woman aged between 25 and 30 was found hanging in a nearby forest, and her death was recorded as suicide.

Grover argued that the immediate burial of the body meant it would never be known whether the woman had died by suicide or whether homicide had preceded the hanging.

The petitioner further referred to the case of a 35-year-old man found dead in a guest house run by the Dharmasthala Trust, alleging that no meaningful effort had been made to establish his identity.

Matter Posted For Hearing

Meanwhile, the State sought time to respond, informing the court that the Advocate General was engaged in another court and would appear in the matter with assistance from the State Public Prosecutor. The Bench accepted the request and posted the matter for further hearing on Aug. 24.

The case stems from an FIR registered on the complaint of a sanitation worker who claimed he had been instructed to bury the bodies of women and children in Dharmasthala between 1995 and 2014. The SIT took over the investigation into the alleged mass burial sites in July 2025.

Apart from seeking excavation and identification of the remains, the PIL also asks the High Court to direct the SIT to register 74 separate first information reports, one for each case listed in the petitioner's representation dated Oct. 11, 2025. It further seeks a direction requiring the SIT to file monthly status reports before the High Court on the progress of the investigation.

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Earlier, in a connected matter, the High Court had orally observed that excavation of human remains could open a "Pandora's box", with more people approaching the court claiming to have seen bodies and seeking similar investigations.

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