Public law compensation for custodial violence requires patent, gross, and incontrovertible proof; unsupported allegations were rejected.

Public law compensation for alleged illegal detention or custodial torture under Article 32 is available only when infringement of Article 21 is patent, gross, and supported by incontrovertible evidence. The Court emphasised that claims of custodial violence must ordinarily be backed by medical records, visible injuries, or other reliable corroboration, and that doubtful, exaggerated, or unsupported allegations do not justify relief. On the facts, the allegations arose during police efforts to trace the petitioner's son, the material did not establish clear custodial torture, and several assertions were found exaggerated or false. Compensation was therefore refused and no further relief granted.

---

---

Issues: Whether compensation should be awarded under Article 32 as a public law remedy for the alleged illegal detention and custodial torture of the petitioner and his relatives.

Analysis: Compensation for violation of Article 21 is available in public law where the infringement is established and is patent, gross, and incontrovertible. The remedy is intended for cases where custodial violence or illegal detention is supported by reliable material, and the Court must act with circumspection where the allegations are doubtful, exaggerated, or unsupported by medical evidence, visible injuries, or other corroboration. On the facts, the allegations arose in the course of police efforts to trace the petitioner's son, the evidence did not show clear or incontrovertible custodial torture, and several claims were found to be exaggerated or false.

Conclusion: Compensation was not warranted, and the petition was disposed of without granting further relief.

Ratio Decidendi: Monetary compensation under Article 32 or Article 226 for custodial violence is available only where infringement of Article 21 is established by patent, gross, and incontrovertible evidence, ordinarily supported by medical or other corroborative material; doubtful, exaggerated, or unsupported claims do not justify public law compensation.

---