Table of Contents
The following landmark judgments explain the legal principles governing an Inquest Report under the Bharatiya Nagarik Suraksha Sanhita (BNSS). These decisions clarify the object, scope, evidentiary value, admissibility, and limitations of an inquest report.
1. Amit Kumar v. Union of India (2025 INSC 384)
Held: It was held that Investigation under Section 174 (now Section 194 of BNSS) is limited in scope and is confined to the ascertainment of the apparent cause of death and should not be equated with investigation into cognizable offences under Sections 160 and 161 of the Cr.P.C. respectively (now Sections 179 and 180 of BNSS respectively). The procedure under Section 174 of the Cr.P.C. (now Section 194 of BNSS) is for the purpose of discovering the cause of death and the evidence taken is very short.
2. Narpal Singh v. State of Haryana (AIR 1977 SC 1066)
Held: It was held that The statements of witnesses made in inquest report are hit by Section 162 of the Code (now Section 181 of BNSS). They are inadmissible in evidence if the signatories were not examined as witnesses.
3. Ritu Chakraborty v. State of Bihar (AIR 2020 SC 3826)
Held: It was held that Proceedings under Section 174 of the Cr.P.C. (now Section 194 of BNSS) are confined to a police inquiry aimed at determining the apparent cause of an unnatural death. They do not constitute a full-fledged investigation as conducted after the registration of an FIR under Section 154 of the Cr.P.C. (now Section 173 of BNSS).
4. Tehseen Poonawalla v. Union of India (2018) 6 SCC 72); Yogesh Singh v. Mahabeer Singh (2017) 11 SCC 195)
Held: It was held that Inquest report is not a substantive piece of evidence. Its purpose is limited to ascertain nature of injuries and cause of death. Its object is to ascertain whether death is suicidal, homicidal, accidental or caused by animals or machinery etc. It states the manner in which or by what weapon or instruments injuries appears to have been inflicted.
