To,
The Chairperson,
National Human Rights Commission (NHRC)
Manav Adhikar Bhawan,
Block-C, GPO Complex, INA,
New Delhi – 110023
Subject: Complaint regarding non-handing over the bodies of the deceased to their families.
Respected Sir,
The Human Rights Forum (HRF) is a citizens’ forum established with the objective of working for the protection of the constitutionally guaranteed/internationally guaranteed rights of the people.
Through this complaint we would like to bring to your urgent attention the inhumane and illegal behavior of Chhattisgarh police in handing over bodies of the deceased to their relatives.
The facts of the case are as follows:
On the morning of May 21, 2025, 27 Maoists were killed in an alleged ‘encounter’ in the Abhujmad area of Chhattisgarh. Among the deceased were General Secretary of CPI (Maoist) Nambala Keshava Rao, along with Sajja Venkata Nageswara Rao (Rajanna), Vannada Vijayalakshmi (Bhumika), Gonegandla Lalitha (Sangeetha), and Burra Rakesh (Vivek) from Andhra Pradesh and Telangana.
Family members of the deceased travelled to Chhattisgarh on May 22 to reclaim the bodies. For five consecutive days, they have been waiting outside the Narayanpur district police station and local hospitals. Despite submitting all the necessary documents, authorities have refused to release the bodies. It is disturbing to note that the bodies have been left exposed to elements in the morgue instead of being stored in morgue coolers. Six days have now passed since the killings.
We would also like to bring to your notice that the families have made every lawful effort to claim the remains—including travelling to Chhattisgarh with ambulances equipped with freezer facilities, approaching police authorities, and filing writ petitions (W.P. Nos. 13928 and 13929 of 2025) before the Hon’ble High Court of Andhra Pradesh. The matter was disposed of vide order dated 24.05.2025 holding as follows:
“Considering the submissions of the learned Senior Counsel appearing for the petitioners, the learned Advocate General for the State of Chhattisgarh and for the State of Andhra Pradesh, this Court without going into the issue of the territorial jurisdiction intends to dispose the writ petitions recording the submissions that the post-mortem of the bodies would be completed today and the next formality is to hand over the dead bodies to the relatives of the deceased for performing final rites.”
Despite informing the honorable High Court that they would hand over the bodies once the postmortem is carried out, the police are now refusing to hand over the bodies claiming “law and order issues” back in Andhra Pradesh and Telangana. As we write this, the relatives of the slain Maoists are being made run from pillar to post in Narayanpur to reclaim the bodies of their loved ones.
The right to perform last rites and bid farewell to one’s loved ones is not a procedural privilege—it is a fundamental, inalienable right protected under Article 21 of the Constitution. The Hon’ble Supreme Court, in Pt. Parmanand Katara v. Union of India, held that dignity in death is as inviolable as dignity in life. The dignity of the dead cannot be held hostage to arbitrary executive discretion or speculative law and order concerns. The speculative assertion that funeral processions might cause unrest—when families have formally offered, in court, to comply with all conditions—cannot justify this indefinite and degrading denial.
Moreover, the State’s conduct gravely violates binding international humanitarian obligations. Common Article 3 of the Geneva Conventions, to which India is a party, mandates humane treatment of all persons not actively participating in hostilities, including the dead. Customary International Humanitarian Law, as codified in the ICRC’s authoritative study, obligates parties to conflict to recover, identify, and return remains to families, and to preserve them with dignity and respect. These rules are not suspended by labelling individuals as “Maoists” or invoking the language of “security operations.” They apply to all parties, at all times.
The NHRC itself, in its 2020 Advisory on the Dignity of the Dead, laid out specific guidelines to ensure the respectful handling of remains, timely autopsies, proper storage, and the facilitation of last rites. The ongoing situation in Narayanpur represents a categorical breach of every one of those standards.
We therefore urge the Hon’ble Commission to:
- Immediately direct the Government of Chhattisgarh to release the remains of the five deceased individuals—Nambala Keshava Rao, Sajja Venkata Nageswara Rao, Vannada Vijayalakshmi, Gonegandla Lalitha, Boora Rakesh —to their respective families without further delay; allow and assist them to take the bodies to their native states to perform final rites; and
- Direct that each of the representatives of the families are provided copies of the Postmortem reports following the NHRC template along with the video graph of the autopsy conducted.
Sincerely,
Atram Bhujanga Rao (HRF Telangana State president)
Dr. S. Thirupathaiah (HRF Telangana State general secretary)
26.05.2025,
Hyderabad.