On 31 July 2025, a 58-year-old tribal man, P. Marimuthu of Mel Kurumalai hamlet in Tiruppur district, Tamil Nadu, was allegedly found dead in the toilet of the Udumalaipet forest range office under Anamalai Tiger Reserve (ATR). He was interrogated on charges of possessing leopard teeth. The family members of the deceased alleged that Marimuthu was beaten to death by the forest officials as there were injuries to his body, including head, arms and neck. Two forest officials were suspended and a judicial enquiry was ordered.[1]
The custodial death of P. Marimuthu is unlikely to be reported to the National Human Rights Commission which in its Guidelines “On Custodial Deaths/Rapes” issued on 14 December 1993 directed that any custodial death or rape – whether in police or judicial custody – must be reported to the Commission within 24 hours by District Magistrates and Superintendent of Police. Delayed reporting gives rise to a presumption of suppression of the incident. In June 1995, the NHRC clarified that reports must include incidents occurring in judicial custody as well.[2]
The Forest Department officials are vested with significant powers of arrest and detention under Section 64 of the Indian Forest Act of 1927, Section 50 of the Wildlife Protection Act, 1972 and various state-specific forest laws. These powers of arrest of the Forest Department officials are abused regularly and lead to custodial deaths. These custodial deaths are not automatically reported to the NHRC as per the Guidelines “On Custodial Deaths/Rapes”. The victims and their relatives suffer and the need to bring the Forest Department officials under the ambit of the Guidelines is of paramount importance.
Custodial deaths have been taking place at the hands of the Forest Department officials but not reported to the NHRC. Some of the reported cases of custodial deaths in addition to P. Marimuthu are given below:
Custodial death of Palanisamy, Tamil Nadu
On 26 July 2025, Palanisamy (48), a wage labourer from Thandampalayam near Punjai Puliampatti in Erode district, Tamil Nadu, died after he was taken in the custody of the forest officials in connection with wildlife hunting. The forest officials from Bhavanisagar range conducted a search at his house on the night of 26 July. During the search, the officials allegedly seized 26 kg of spotted deer meat, two deer antlers and hunting snares. Thereafter, the officials claimed that they attempted to take him to the forest office for questioning. At that point, Palanisamy allegedly requested to use the toilet. The officials reportedly agreed. The officials claimed that Palanisamy consumed pesticide while in the toilet and then accompanied the officials. The forest department officials were allegedly unaware of this at the time. Palanisamy began vomiting shortly after reaching the Bhavanisagar range office. Palanisamy’s family reportedly called the forest officials and informed them that he had consumed pesticide after discovering this in the toilet. The officials then rushed him to the Government Hospital in Sathyamangalam for treatment. However, Palanisamy died at the hospital. A judicial enquiry was ordered into the matter of 27 July 2025.[3]
Custodial death of 59-year-old Dhaneswar Behera, Odisha
On 5 February 2023, a 59-year-old man identified as Dhaneswar Behera died in the custody of the forest department allegedly after being detained on suspicion of poaching a tusker in the Athagarh area in Cuttack district, Odisha. Dhaneswar was picked up by forest officials while he was returning from his daughter’s house on the night of 5 February 2023. Following his death, angry villagers, including his wife alleged he was beaten to death by forest officials. In protest, they blocked a road and set fire to a forest beat house.[4]
Custodial death of 49-year-old tribal Kariyappa, Karnataka
On 12 October 2022, 49-year-old tribal man named Kariyappa from Hosahalli hamlet in H.D. Kote taluk in Mysuru district, Karnataka died in the custody of forest department officials after being detained on allegations of possessing deer meat. He had been held at an anti-poaching camp by forest staff under the Gundre Forest Range since 10 October 2022. Forest officials claimed Kariyappa was already unwell and died of illness after being rushed to K R Hospital. However, his family and fellow villagers alleged he was tortured, citing visible injury marks on his body. A relative, Ramya, said forest guards picked him up from near her house and they were later abruptly informed of his death.[5]
Custodial death of a tribal Maniram Gond, Madhya Pradesh
On 19 July 2020, a tribal identified as Maniram Gond (40 years) died due to alleged harassment by the Forest Department officials in Dhana area of Sagar district in Madhya Pradesh. The villagers staged a road blockade on the morning of 19 July by placing the dead body on the road and accused forest range officer Devesh Gautam of subjecting Maniram Gond to harassment in connection with a seizure case. The accused forest officer allegedly demanded a bribe of Rs 100,000 from Maniram Gond to free his seized tractor-trolley. According to the deceased’s wife Ashok Rani, her husband went to meet the ranger Devesh Gautam with Rs 30,000 on 18 July 2020 but the officer refused to accept anything less than Rs 100,000. The officer allegedly scolded the tribal farmer and while returning he suffered cardiac arrest and died.[6]
Custodial death of 70-year-old Anaikarai Muthu, Tamil Nadu
On 23 July 2020, a 70-year-old farmer identified as Anaikarai Muthu, accused of installing illegal electric fence in his farmland, died due to alleged torture in the custody of Kadayam Forest Range officials in Tenkasi district of Tamil Nadu. According to the deceased’s son, A Natarajan, five Forest Department officials came to their house in a jeep around 11.30 pm on 22 July and took his father to the forest office in Sivasailam. He was declared brought dead at the Government Headquarters Hospital in Tenkasi around 1.30 pm on 23 July. A Natarajan alleged that his father was tortured by the Forest Department officials and he filed a case against them at the Alwarkurichi police station. The deceased’s wife Palammal filed a petition in the Madras High Court seeking Crime Branch-Criminal Investigation Department inquiry in the custodial death of her husband. In her petition she stated that Muthu did not have any health complication or illness and had died due to custodial torture by the Forest Department officials. On 30 July, the Madurai bench of the Madras High Court ordered a re-postmortem on the body of Anaikkarai Muthu to be conducted by a team consisting of the heads of the department of Forensic Science at the Tirunelveli and Thoothukudi Medical Colleges and a professor from Tirunelveli Medical College. The court ordered that the autopsy will have to be conducted following all the guidelines laid down by NHRC.[7]
Custodial death of Balabhadra Behera, Odisha
On 13 October 2020, Balabhadra Behera (46 years) died due to alleged torture by the Forest Department officials of Banpur Niladriprasad forest in Khordha district of Odisha. The deceased, a resident of Golagaon village under Odagaon Tehsil in Nayagarh district, was arrested on 13 October by the Forest Department officials from the jungle in connection with a theft case. The suspect died in suspicious circumstances at Banpur hospital on 14 October. The police claimed that the deceased was arrested by the forest patrolling team of Banpur’s Niladriprasad forest under Balugaon range and the deceased suddenly fell ill during custody following which he was admitted to Banpur hospital but succumbed during treatment on 13 October. However, the deceased’s family members alleged that the deceased was tortured by the Forest Department officials during custody which caused his death.[8]
Custodial death of PP Mathai, Kerala
On 28 July 2020, PP Mathai, a 41-year-old farmer from Chittar, Pathanamthitta in Kerala, was found dead in a well on his farm, just hours after forest officials took him in for questioning over the alleged destruction of a camera set up by the department for animal-spotting. Mathai’s family alleged that he died in custody.[9]
Supreme Court direction for installation of CCTV cameras in all interrogation rooms of any other agency which carries out interrogations and has the power of arrest
The Supreme Court in its judgment in Paramvir Singh Saini vs Baljit Singh[10] [AIR 2021 SUPREME COURT 64] on 2 December 2020 ruled the installation of CCTV cameras in police stations, and in the offices of any other agency which carries out interrogations and has the power of arrest across the country. The apex court also directed the Union of India to install CCTV cameras and recording equipment in the offices of (i) Central Bureau of Investigation (CBI), (ii) National Investigation Agency (NIA), (iii) Enforcement Directorate (ED), (iv)Narcotics Control Bureau (NCB), (v) Department of Revenue Intelligence (DRI), (vi) Serious Fraud Investigation Office (SFIO), and (vii) any other agency which carries out interrogations and has the power of arrest.
Repeated instances of custodial deaths, torture and abuse by forest officials highlight a systemic gap in accountability. Despite exercising police-like powers, forest officials are not subject to the same mandatory reporting requirements to the NHRC as police personnel.
As conservation policies increasingly involve stricter enforcement measures, tribal communities, many of whom depend on forests for their livelihoods, are at increased risk of arbitrary arrest, torture and even death in custody. These incidents take place in the remote/forest areas and not all cases are reported in the news media.
Unless the Forest Department is brought under the ambit of the NHRC’s custodial death/rape guidelines and all allegations of abuse are subjected to independent judicial inquiries, these violations are likely to continue with impunity.
[1]. Two forest staff suspended over death of ST man, The New Indian Express, 2 August 2025, https://www.newindianexpress.com/states/tamil-nadu/2025/Aug/02/two-forest-staff-suspended-over-death-of-st-man
[2]. See NHRC Guidelines on Custodial Deaths/Rapes, available at https://www.mha.gov.in/sites/default/files/2022-12/NHRCselectedlettersandguidelinesondeathsincustody_09042019_0%5B1%5D.pdf
[3]. 48-year-old wage labourer dies by suicide after forest officials allegedly find deer meat at his residence, The New Indian Express, 27 July 2025, https://www.newindianexpress.com/states/tamil-nadu/2025/Jul/27/48-year-old-wage-labourer-dies-by-suicide-after-forest-officials-allegedly-find-deer-meat-at-his-residence
[4]. Odisha Man Dies In Forest Department Custody, Mob Sets Beat House On Fire, NDTV, 6 February 2023, https://www.ndtv.com/india-news/odisha-man-dies-in-forest-department-custody-mob-sets-beat-house-on-fire-3757207
[5]. Karnataka: Tribal man in foresters’ custody dies of suspected torture in HD Kote, The New Indian Express, 13 October 2025, https://www.newindianexpress.com/states/karnataka/2022/Oct/13/karnataka-tribal-man-in-foresters-custody-dies-of-suspected-torture-in-hd-kote-2507545.html
[6]. India Annual Report on Torture-2020, National Campaign Against Torture, 18 March 2021, https://www.uncat.org/wp-content/uploads/2021/03/IndiaTortureReport2020.pdf
[7]. India Annual Report on Torture-2020, National Campaign Against Torture, 18 March 2021, https://www.uncat.org/wp-content/uploads/2021/03/IndiaTortureReport2020.pdf
[8]. India Annual Report on Torture-2020, National Campaign Against Torture, 18 March 2021, https://www.uncat.org/wp-content/uploads/2021/03/IndiaTortureReport2020.pdf
[9]. Two Kerala forest officials suspended in alleged custodial death of farmer, The News Minute, 3 August 2020, https://www.thenewsminute.com/kerala/two-kerala-forest-officials-suspended-alleged-custodial-death-farmer-129961
[10]. Paramvir Singh Saini vs Baljit Singh judgment is available at https://indiankanoon.org/doc/88573149/
