The conviction of nine policemen in the Jayaraj–Benicks case is a rare moment of reckoning. But one verdict, however significant, does not dismantle the system that made their deaths possible.
There is a particular kind of horror that attaches to deaths that occur inside a police station — not on a battlefield, not in the chaos of a riot, but in a small locked room in a government building where the state is supposed to be protecting the very person it is holding. The killing of P. Jayaraj and his son J. Benicks at the Sattankulam police station in Thoothukudi, Tamil Nadu, in June 2020 was that kind of horror. The two men were picked up, stripped, beaten overnight with savage brutality, forced to clean their own blood from the floor, produced before a doctor who issued a fitness certificate they were manifestly unfit to receive, and then remanded to judicial custody by a magistrate who asked no difficult questions. Within days, both were dead. It took five years, the courage of a single witness in uniform, and the persistence of investigators to reach what a trial court in Madurai has now delivered: the conviction of all nine surviving accused policemen.
That conviction is a landmark. In the way that such landmarks tend to be in India, it is also a reminder of how exceptional it is for the justice system to function as it should and how many custodial deaths never arrive at any reckoning at all.
The Case
How a Routine Detention Became a Crime
The facts of the Sattankulam case are both specific and depressingly familiar in their outline. Jayaraj, a trader in his fifties, was picked up by police on the night of June 19, 2020, on charges of allegedly violating lockdown conditions during the COVID-19 pandemic — a charge that, even if true, carried no legal penalty remotely commensurate with what followed. His son Benicks, who came to the station the next morning to confront the officers for assaulting his father, was detained as well. What happened inside the station over the following hours was documented only partially, but the CBI’s investigation eventually pieced together a picture from blood samples matched to the victims’ DNA, call data records placing both accused and victims at the station, and crucially, the testimony of a head constable named Revathi who broke ranks with her colleagues and told the truth.
The two men were presented before a jurisdictional magistrate — who remanded them to judicial custody without inquiring into their evident physical condition — and died within days. A Judicial Magistrate who later visited the station described the atmosphere as “hostile and intimidating.” The Madurai Bench of the Madras High Court, acting on suo motu cognisance taken by Justices P.N. Prakash and B. Pugalendhi, ordered revenue officials to take control of the station to safeguard evidence before it could be further destroyed. The institutional instinct to cover up was visible at every stage; so, ultimately, was the institutional capacity to resist it.
The Sattankulam Verdict — Key Facts
A trial court in Madurai convicted all nine surviving policemen on the basis of CBI scientific evidence. A tenth accused had died of COVID-19 during the pendency of the case. The court awarded the death penalty to the convicts — a decision likely to face scrutiny in higher courts, given established doctrine on proportionality in capital sentencing. The conviction nonetheless sends a message that custodial violence will not be shielded by institutional loyalty alone.
The Law
A Constitution That Forbids It, a Statute Book That Barely Names It
One of the more striking features of India’s legal framework on custodial violence is how thoroughly the Constitution prohibits it in principle, and how poorly the statutory law has historically defined and punished it in practice. Article 21 guarantees the right to life and personal liberty to every person — not merely every citizen — and the Supreme Court has consistently held that this right encompasses freedom from torture and inhuman treatment. Article 20(3) protects individuals from being compelled to incriminate themselves, thereby expressly recognising the danger that coercion in custody poses. Article 20(1) prohibits excessive or retrospective punishment. Taken together, these provisions erect a constitutional wall against custodial abuse. The wall is frequently breached.
For decades, India had no dedicated statute defining or criminalising custodial torture. The term “custodial violence” — which covers physical assault, psychological harm, humiliation, sexual violence, and death occurring while a person is under police or judicial custody — appeared in no Indian statute. The Bharatiya Nyaya Sanhita of 2023 has made some progress, penalising those who intentionally cause hurt or grievous hurt to extract confessions or information through violence or coercion. The Bharatiya Nagarik Suraksha Sanhita classifies custody into police custody, capped at fifteen days for interrogation, and judicial custody involving detention in prison. But critics note that these provisions, while welcome, fall well short of a comprehensive anti-torture law.
Delivery of justice to hapless victims of police brutality requires a combination of an actively engaged judiciary, the courage of victims and witnesses to speak out, and a determined investigation to assemble irrefutable evidence
The Gap
India’s Long Refusal to Ratify UNCAT
India signed the United Nations Convention Against Torture in 1997. Nearly three decades later, it has still not ratified it. The Law Commission of India, in its 273rd Report in 2017, urged the government to ratify the Convention and enact a standalone law criminalising torture — a recommendation that has gathered dust with notable consistency across successive administrations. The International Covenant on Civil and Political Rights, which India did ratify in 1979, affirms that prisoners must be treated with dignity and that their fundamental rights remain protected even in custody. The gap between treaty obligation and domestic reality has been a persistent feature of India’s human rights landscape.
The Supreme Court, in the 2020 case of Paramvir Singh Saini vs. Baljit Singh, directed the installation of CCTV cameras and recording systems in all police stations across the country to deter custodial torture and provide evidentiary records when it occurs. The direction was significant; its implementation has been uneven. In the Sattankulam case, the absence of functioning surveillance technology at the station was itself part of the problem — it allowed what happened overnight to remain hidden until the CBI’s forensic work reconstructed it.
The System
Why Custodial Violence Persists
Any honest account of why custodial deaths continue to occur in India must grapple with structural factors that a single conviction, however significant, does not address. The police force operates under conditions of severe under-staffing, inadequate training, and a performance culture that historically measured effectiveness by the speed of confessions rather than the quality of investigation. In this culture, the body of a suspect in a locked room can come to seem like a shortcut to a solved case — and the institutional machinery around the police has, too often, been oriented toward protecting that shortcut rather than eliminating it.
Magistrates who mechanically remand obviously injured detainees, doctors who issue fitness certificates without examination, senior officers who look away, colleagues who maintain silence — the Sattankulam case implicated all of these actors, not just the nine men ultimately convicted. The case succeeded partly because all the usual mechanisms of suppression eventually failed: evidence was not fully destroyed, a witness found her conscience, the High Court moved swiftly, and the CBI was thorough. None of those things can be assumed to happen in the hundreds of custodial death cases that are registered each year across the country and proceed to no comparable outcome.
The Path Forward
What Justice Requires Beyond the Verdict
The conviction in the Sattankulam case will almost certainly face appeals, and the death sentences awarded by the trial court will receive close scrutiny from higher courts applying the “rarest of rare” doctrine. The Supreme Court’s 1999 ruling in the Rajiv Gandhi assassination case, where it upheld death sentences for only four of the twenty-six persons convicted by the TADA court, suggests that proportionality arguments will be heard carefully. The convictions themselves — the finding of guilt — are the more durable and significant achievement.
What the case demonstrates, above all, is that accountability for custodial violence is possible when the conditions align: an independent judiciary willing to act suo motu, investigators insulated from local police pressure, forensic evidence preserved and competently examined, and at least one person inside the system willing to tell the truth. The challenge for Indian democracy is to make those conditions less exceptional — to build them into the ordinary functioning of the justice system rather than leaving them to chance and courage. That requires ratifying UNCAT, enacting a dedicated anti-torture statute, operationalising CCTV mandates uniformly, and reforming magistrate oversight of remand proceedings. Jayaraj and Benicks deserved all of that. So do the countless others whose names never made the headlines.
