Disposed¶48

The Principal Secretary v. M.Jeya

Custodial death compensation – quantum challenge by State

Madras HC7 Jan 2026WA(MD)/823/2024

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Case brief

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What is this about?

Writ Appeal (W.A(md)No.823 of 2024), Madurai Bench of Madras High Court, 07.01.2026, Coram: Dr. Justice G.Jayachandran (author) and Justice K.K.Ramakrishnan. State appeal against Rs.25,00,000 custodial-death compensation; Pranay Sethi multiplier formula; erroneous multiplier 18 vs 16; compensation reduced/modified to Rs.23,00,000; balance Rs.18,00,000 payable with 6% interest from 27.09.2024; Clause 15 Letters Patent; C.M.P(MD)Nos.6104 of 2024 and 16736 of 2025 closed.

What did the court decide?

Appellants/State directed to pay the first respondent/writ petitioner Rs.18,00,000/- with 6% interest from 27.09.2024 till the date of payment, within 30 days; compensation modified to Rs.23,00,000/-; no costs; connected miscellaneous petitions closed. ¶48

The Principal Secretary Vs M.Jeya — Madras HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

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Issue for consideration

Whether the compensation of Rs.25,00,000/- fixed by the learned single Judge for the custodial death of the writ petitioner's son is on the higher side and computed with an improper multiplier under the principle laid down in Pranay Sethi.

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Court's answer

While paying compensation in the case of a custodial death, the Court cannot be very strict in applying the (Pranay Sethi) formula.

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Ratio / Principle

The learned Single Judge erroneously applied multiplier '18'; the correct multiplier was '16', the deceased having been only 17 years old on the date of the accident.

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Key takeaways

Even according to the formula adopted by the learned single Judge, the compensation would be only Rs.22,98,000/-, which should be rounded off to Rs.23,00,000/-; the compensation awarded is accordingly modified from Rs.25,00,000/- to Rs.23,00,000/-.ratio¶47
The writ appeal is disposed of directing the appellants/State to pay the first respondent/writ petitioner Rs.18,00,000/- (after crediting Rs.5,00,000/- already paid) with 6% interest from 27.09.2024 till the date of payment, within 30 days; no costs; connected miscellaneous petitions closed.ratio¶48

Detailed headnote1 paragraphs

Custodial death compensation - quantum challenge by State - Writ Appeal under Clause 15 of Letters Patent against single Judge's order dated 18.08.2023 in W.P(MD)No.5259 of 2021 awarding Rs.25,00,000/- to the mother of a deceased (aged 17) who died in custody. Held, applying the multiplier principle in National Insurance Co. Ltd. v. Pranay Sethi, 2017(2) TN MAC 609(SC): while in custodial death cases the Court cannot be very strict in applying the formula, the multiplier '18' applied by the single Judge was erroneous and '16' was appropriate; even on the formula adopted below the compensation computes to only Rs.22,98,000/-, rounded off to Rs.23,00,000/-. Taking note that Rs.5,00,000/- had already been paid and the balance deposited in Canara Bank, Thallakulam Branch on 27.09.2024, the Bench disposed of the appeal directing the State to pay Rs.18,00,000/- with 6% interest from 27.09.2024 till payment, within 30 days. No costs; connected miscellaneous petitions closed.

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W.A(md)No.823 of 2024

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BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT

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Dated:07.01.2026

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CORAM

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THE HONOURABLE DR.JUSTICE G.JAYACHANDRAN

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AND

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THE HONOURABLE MR.JUSTICE K.K.RAMAKRISHNAN

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WA(MD)No.823 of 2024 and

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C.M.P(MD)Nos.6104 of 2024 and 16736 of 2025

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1.The Principal Secretary,

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Home Department, Government of Tamil Nadu, Secretariat,

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Chennai-600 009.

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2.The Principal Secretary,

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Public Department, Government of Tamil Nadu, Secretariat,

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Chennai-600 009.

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3.The Director General of Police, Director General of Police Office Mylapore,

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Dr.Radhakrishnan Salai,

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Chennai-600 004.

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4.The Additional Director General of Police, Crime Branch Crime Investigation Department,(C.B.C.I.D) No.220, Pantheon Road, Egmore,

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Chennai-600 008.

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https://www.mhc.tn.gov.in/judis

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W.A(md)No.823 of 2024

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5.The Commissioner of Police, Commissioner of Police Office, Madurai City, Madurai-625 001.

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6.The Inspector of Police, S.S.Colony Police Station, Madurai City, Madurai-625 001

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7.The District Collector, Collector Office, Madurai-625 020.

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8.The Tahsildar Office, South Taluk Office, Madurai District.

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9.The Superintendent of Police(South Zone) Crime Branch Crime Investigation Department,(C.B.C.I.D) No.220, Pantheon Road, Egmore, Chennai-600 008.

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10.The Deputy Superintendent of Police,

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Crime Branch Crime Investigation Department (C.B.C.I.D) No.7, Kamarajar First Street, Chinna Chokkikulam, Madurai-625 002. ... Appellants/Respondents

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Vs.

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M.Jeya ...Respondent/Petitioner

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Prayer : Writ Appeal filed under Clause 15 of Letters Patent, to set aside the order dated 18.08.2023 passed in W.P(MD)No.5259 of 2021 on the file of this Court.

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https://www.mhc.tn.gov.in/judis

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W.A(md)No.823 of 2024

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For A1, A2, A7&A8: Mr.Veera Kathiravan,

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Additional Advocate General, assisted by Mr.S.R.A.Ramachandran, AGP, For A3 to A6,A9&A10:Mr.K.Gnanasekaran, Govt., Advocate (Crl.side)

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For Respondent : Mr.R.Karunanithi *****

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JUDGMENT

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(Judgment of the Court was delivered by DR.G.JAYACHANDRAN,J.)

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The appeal is by the State being aggrieved on a short point for the compensation given to the mother of the deceased based on the Principle laid down by the National Insurance Company Limited Vs. Pranay Sethi and Others , reported in 2017(2) TN MAC 609(SC) , for the custodial death of the writ petitioner's son, is on the higher side and not applying proper multiplier.

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2.The learned Additional Advocate General submitted that the compensation of Rs.25,00,000/- had been fixed by the learned single Judge, even though the compensation calculated applying Pranay Sethi case , is only Rs.22,98,000/-. He further submitted that the multiplier '18' applied by the learned single Judge is erroneous, since the age of the deceased was only 17 years on the date of the accident.

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https://www.mhc.tn.gov.in/judis

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W.A(md)No.823 of 2024

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3.This Court is of the view that while paying compensation in the case of a custodial death, we cannot be very strict in applying the formula and though the learned Single Judge has erroneously applied the multiplier '18' instead of '16', we do not want to interfere with the compensation awarded, except to say that even according to the formula adopted by the learned single Judge, the compensation will be only Rs.22,98,000/- and should be rounded off to Rs.23,00,000/-, hence, we modify the compensation amount to Rs.23,00,000/-. The learned Additional Advocate General submits that already Rs.5,00,000/- had been paid to the writ petitioner. The balance amount is deposited in Canara Bank, Thallakulam Branch, on 27.09.2024.

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4.Taking note of the said fact, we dispose of the writ appeal directing the appellants/State to pay the first respondent/writ petitioner a sum of Rs.18,00,000/- with 6% interest from 27.09.2024 till the date of payment. The payment should be made within 30 days from today. No costs. Consequently, connected miscellaneous petitions are closed.

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[G.J., J.] & [K.K.R.K., J.] 07.01.2026

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Index :Yes/No Internet :Yes Ns

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https://www.mhc.tn.gov.in/judis

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W.A(md)No.823 of 2024

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1.The Principal Secretary, Home Department, Government of Tamil Nadu, Secretariat, Chennai-600 009. 2.The Principal Secretary, Public Department, Government of Tamil Nadu, Secretariat, Chennai-600 009. 3.The Director General of Police, Director General of Police Office Mylapore, Dr.Radhakrishnan Salai, Chennai-600 004. 4.The Additional Director General of Police, Crime Branch Crime Investigation Department,(C.B.C.I.D) No.220, Pantheon Road, Egmore, Chennai-600 008. 5.The Commissioner of Police, Commissioner of Police Office, Madurai City, Madurai-625 001. 6.The Inspector of Police, S.S.Colony Police Station, Madurai City, Madurai-625 001 7.The District Collector, Collector Office, Madurai-625 020. 8.The Tahsildar Office, South Taluk Office, Madurai District. 9.The Superintendent of Police(South Zone) Crime Branch Crime Investigation Department,(C.B.C.I.D) No.220, Pantheon Road, Egmore, Chennai-600 008. 10.The Deputy Superintendent of Police, Crime Branch Crime Investigation Department (C.B.C.I.D) No.7, Kamarajar First Street, Chinna Chokkikulam, Madurai-625 002.

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https://www.mhc.tn.gov.in/judis

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W.A(md)No.823 of 2024

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DR.G. JAYACHANDRAN, J. AND K.K. RAMAKRISHNAN, J.

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WA(MD)No.823 of 2024 and C.M.P(MD)No.6104 of 2024

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07.01.2026