PAVUL YESU DHASAN versus THE REGISTRAR, STATE HUMAN RIGHTS COMMISSION OF TAMIL NADU & ORS.

PAVUL YESU DHASAN versus THE REGISTRAR, STATE HUMAN RIGHTS COMMISSION OF TAMIL NADU & ORS.

Refusal by the police officer to register the FIR combined with the use of very objectionable language towards the complainant's mother violated the individual's right to human dignity under Article 21 and falls within the definition of 'human rights' in Section 2(d) of the Human Rights Act, 1993; therefore the Commission's award of compensation was rightly upheld and the appeal was dismissed.

Parties
Appellant: Pavul Yesu Dhasan; Respondents: The Registrar, State Human Rights Commission of Tamil Nadu & Ors.; Respondent/complainant: Third respondent-complainant
Jurisdiction
India
Judgment Date
30 April 2025
Procedural Posture
Civil Appeal / Judgment of the Supreme Court (appeal Dismissed)
Outcome
Appeal dismissed
Legal Topics
Refusal to Register FIR, Violation of Human Rights, Compensation, Human Dignity, Non Registration of FIR, Objectionable Language by Police
Constitutional Law Human Rights Act, 1993 Criminal Law/procedure Refusal to Register FIR Violation of Human Rights Compensation Human Dignity Non Registration of FIR +1 more

Case Brief

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Parties

Pavul Yesu Dhasan

Appellant

The Registrar, State Human Rights Commission of Tamil Nadu & Ors.

Respondents

Third respondent-complainant

Respondent/complainant

Procedural Posture

Civil Appeal / Judgment of the Supreme Court (appeal Dismissed)

Legal Issues

  1. 1 Whether refusal by a police officer to register an FIR and use of objectionable language towards a complainant/relative constitutes violation of 'human rights' under Section 2(d) of the Human Rights Act, 1993 and Article 21 of the Constitution
  2. 2 Whether the State Human Rights Commission's order directing the Excise Department to pay compensation with liberty to recover from the appellant was maintainable

Ratio Decidendi

Refusal by the police officer to register the FIR combined with the use of very objectionable language towards the complainant's mother violated the individual's right to human dignity under Article 21 and falls within the definition of 'human rights' in Section 2(d) of the Human Rights Act, 1993; therefore the Commission's award of compensation was rightly upheld and the appeal was dismissed.

Court Disposition

Appeal dismissed

Orders

  • Appeal dismissed.
  • State Human Rights Commission order directing the Additional Chief Secretary, Home, Prohibition and Excise Department to pay compensation of Rs.2,00,000/- to the third respondent-complainant with liberty to recover the said amount from the appellant is upheld.