The National Human Rights Commission (NHRC), India, has issued a Show Cause Notice under Section 18 of the Protection of Human Rights Act, 1993, to the Chief Secretary, Government of Bihar, in connection with the custodial death of Ashok Manjhi in Bihar.
The notice follows a complaint filed by Lenin Raghuvanshi, human rights defender and Founder-Convenor of the People’s Vigilance Committee on Human Rights (PVCHR), concerning the alleged custodial death that occurred in Sarmera Husaina Police Station area, Bihar.
Background of the Case
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Victim: Ashok Manjhi (39 years)
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Date of incident: 07 November 2022
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Place: Sarmera Husaina Police Station area, Bihar
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Allegation: Custodial death following police torture
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NHRC Case No.: 68/4/22/2023-ad
Ashok Manjhi was reportedly picked up by the police in connection with an excise-related case. While in police custody, he sustained a head injury and later died during treatment on 10 November 2022.
Although the police claimed that the injury was accidental—caused by a fall from a vehicle—the NHRC observed that:
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The deceased was in police custody at the time of the incident.
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The police had a duty of care to ensure his safety.
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The post-mortem report confirmed death due to haemorrhagic shock caused by head injury from a hard blunt object.
The Commission concluded that the State is vicariously liable for the custodial death due to police negligence.
NHRC Findings on the Condition of the Children
Following the death of Ashok Manjhi and his wife Golaki Devi, the NHRC Investigation Division conducted a spot enquiry (18–22 August 2025) and found:
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Four minor children (aged 9 to 14 years) are living with their maternal grandmother, who is 70 years old and completely blind.
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The eldest child works as a daily wage labourer and is the sole breadwinner.
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None of the children is enrolled in school.
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The children are not receiving benefits under most government welfare schemes.
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The family lives in extreme poverty, without adequate food, healthcare, housing, or education.
The NHRC noted a serious failure of the Child Welfare Committee and district administration in ensuring protection and rehabilitation of the orphaned children under the Juvenile Justice Act.
Compensation Recommended by NHRC
The NHRC has directed the Chief Secretary, Government of Bihar, to show cause within four weeks as to why compensation should not be paid.
💰 Compensation Amount
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₹7,50,000 (Seven Lakh Fifty Thousand Indian Rupees)
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Approximately USD 9,000–9,100 (based on prevailing exchange rates)
This compensation is to be paid to the next of kin of the deceased for the violation of Ashok Manjhi’s human rights.
Accountability of Police Officials
In addition to compensation, the NHRC has directed that:
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The Director General of Police, Bihar, must inform the Commission within four weeks about departmental action taken against the police officials responsible for the custodial lapse.
PVCHR’s Position
PVCHR welcomes the NHRC’s clear acknowledgment that:
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Custodial safety is a non-negotiable constitutional obligation.
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Deaths in custody demand strict accountability, not administrative excuses.
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Orphaned children of custodial death victims require urgent rehabilitation, not delayed assurances.
However, PVCHR reiterates that monetary compensation alone is not justice. Justice requires:
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Criminal accountability of erring officials,
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Long-term rehabilitation and education of the children,
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Structural reforms to prevent custodial violence.
Conclusion
The NHRC’s Show Cause Notice in the Ashok Manjhi case is a significant step toward accountability, but it also exposes the persistent reality of custodial violence and systemic neglect in India.
PVCHR calls upon the Government of Bihar to:
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Accept the NHRC’s recommendations without delay,
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Ensure immediate disbursement of compensation,
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Guarantee education, care, and protection of the orphaned children,
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Take strict departmental and criminal action against responsible officials.
Custodial death is not an accident—it is a failure of the State.
Date: Mon, Jan 19, 2026 at 3:18 PM
Subject: Show Cause Notice Issued (SCN) - 68/4/22/2023-ad
To: <cs-bihar@nic.in>
Cc: <pvchr.adv@gmail.com>
| NATIONAL HUMAN RIGHTS COMMISSION |
| MANAV ADHIKAR BHAWAN BLOCK-C, GPO COMPLEX, INA, NEW DELHI- 110023 |
| Fax No.: 011-24651332 Website: www.nhrc.nic.in |
| (Law Division) |
| Case No.- 68/4/22/2023-ad |
| Date : 19/01/2026 |
| To, |
| THE CHIEF SECRETARY GOVERNMENT OF BIHAR, MAIN SECRETARIAT, 4, DESHARTAN MARG, RAJBANSI NAGAR, PATNA, BIHAR BIHAR BIHAR Email- cs-bihar@nic.in |
| Sir/ Madam, |
| The case No. 68/4/22/2023-ad in respect of LENIN RAGHUVANSHI, was placed before the Commission on 07/01/2026. Upon perusing the same, the Commission directed as follows: |
| The complainant, an Human Rights Defender, vide complainant dated 10.01.2023 brought to the notice of the Commission regarding alleged death of Ashok Manjhi in Sarmera Husaina PS, District Munger, on 07.11.2022. The Commission took cognizance of the matter and sought requisite reports in the matter from the DGP, Bihar, District Magistrate and SSP, Munger in accordance with the guidelines laid down by the Commission. Upon receipt of the said reports, the same were sent to the Investigation Division for examination, who recommended to issue directions to the DGP, Bihar to get the matter enquired by CID and furnish the report by the head of CID (ADG) within four week’s time. Considering the recommendation made by the Investigation Division to ascertain the status of the five children, who are minors and orphaned, the Commission by its order dated 16.07.2025, directed as under:- (i) to find out whether the Child Welfare Committee of the District was informed of this incident; (ii) whether the Child Welfare Committee has taken appropriate steps as required by Juvenile Justice Act; (iii) the present whereabouts of the children and the persons under whose custody the children are being brought up; (iv) the rehabilitation measures, if any provided to the children through the Child Welfare Committee; and (v) the officers so deputed, shall also obtain copies of the ICP and SIR, if they are available and direct submission of these reports if they have so far not prepared. In compliance to the above directions, a sport enquiry was conducted by a team of Investigation Division from 18.08.2025 to 22.08.2025:- 1. After the death of Ashok Manjhi and his wife Golaki Devi, their four children - Shiv Kumar (14 yrs), Rajanandani Kumari (12 yrs), Dhanraj Kumar (10 yrs), and Chandani Kumari (9 yrs) are residing with their maternal grandmother, Smt. Tusiya Devi (70yrs), who is completely blind and unable to care for them. 2. The eldest son, Shiv Kumar, works as a daily wage labourer and is the sole breadwinner of the family. 3. Although their grandmother is considered the guardian in records, in reality, she is dependent on the children and a liability rather than a support. 4. None of the children is enrolled in school, nor are they availing the benefits of any government scheme, except for the widow pension and free ration. 5. The family is living in extremely pathetic conditions, lacking adequate food, education, medical care, a healthy environment, and proper housing. 6. After having taken the documents and statements of the concerned, it has been ascertained that the children are living in abject poverty and the police and the district administration have assured that the children would be extended benefits of the Government Schemes. The Investigation Division has recommended issuing directions to the Chief Secretary to the Govt. of Bihar to ensure that the desired benefits reach the orphaned children and to submit a compliance report. In view of the recommendations made by the Investigation Division, a notice may be issued to the Chief Secretary to the Government of Bihar to submit an action taken report on the aforesaid recommendations with regard to the government welfare measures provided to the orphaned children. The requisite report shall be received within a period of four weeks. With regard to the death of Ashok Manjhi, the Commission notes that he was picked up by the police along with another person on 07.11.2022, and a case under the Excise Act was registered against him. When his wife went to see Ashok Manjhi, she found him unconscious with a head injury. Thereafter, the police shifted him to Dharhara Hospital, where he died on 10.11.2022 while undergoing treatment. The family members alleged that his death was the result of police torture. It was alleged that the deceased, along with another person, was picked up by the police and taken in an auto/tempo, and during enroute he fell down from the vehicle and sustained a head injury. As per the police version, the incident was accidental. However, there was no other injury on the body of the deceased except the head injury. The post-mortem examination report revealed a lacerated wound over the mid-occipital region measuring ½ × ½ cm, muscle deep, situated about 4 cm behind both ears, surrounded by an abraded area measuring 3 × 3 cm. The cause of death was opined to be haemorrhagic shock and its complications due to head injury caused by a hard blunt object. It appears from the records that the deceased was picked up by the police from his home and was in police custody at the time of the incident. It was, therefore, the responsibility of the police to ensure his safety while in custody. Due to negligence on the part of the police, the deceased sustained a head injury and subsequently died. For this lapse, the State is vicariously liable to compensate the next of kin of the deceased. Accordingly, a notice u/s 18 of the Protection of Human Rights Act, 1993, be issued to the Chief Secretary to the Government of Bihar, calling upon him to show cause within four weeks as to why a sum of Rs. 7.5 lakhs (Rupees Seven Lakhs Fifty Thousand only) should not be recommended to be paid to the next of kin of the deceased towards compensation for violation of his human rights. The Director General of Police, Bihar, shall also inform the Commission within four weeks as to the departmental action taken against the erring police officials in connection with the death of the deceased. Call after four weeks. |
| 2. This is for your information and further necessary action. |
Your’s faithfully |
| CC to |
Complainant Details Indrajeet Kumar |

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