Explained: Why Jharkhand HC refused to modify order for probe against former Gumla SPs in missing minor case
Ranchi, June 27: The Jharkhand High Court’s June 18 order refusing to modify its earlier directions in the Gumla missing minor case…
Ranchi, June 27: The Jharkhand High Court’s June 18 order refusing to modify its earlier directions in the Gumla missing minor case underscores the judiciary’s concern over alleged police apathy in handling crimes involving children. The Division Bench of Justice Sujit Narayan Prasad and Justice Sanjay Prasad held that whether senior police officials failed in their duties can only be determined through an independent fact-finding inquiry, particularly in view of the victim’s mother’s allegation that she repeatedly approached the police for nearly two years before an FIR was finally registered.
The order came on an interlocutory application filed by the Director General of Police (DGP), Jharkhand, seeking partial modification of the High Court’s May 12, 2026, order, which had directed the Principal Secretary, Home Department, and the DGP to inquire into the role of former Gumla Superintendents of Police (SPs) and investigating officers who handled the case between 2018 and 2022.
What is the case about?
The case relates to the disappearance of a minor girl from Gumla district in 2018.
According to the writ petition filed by her mother, the girl went missing around August 2018. The petitioner alleged that despite repeatedly approaching the district police for nearly two years, no effective action was taken to trace her daughter.
An FIR was eventually registered on February 6, 2020, at the Anti-Human Trafficking Unit (AHTU), Gumla, under provisions of the Indian Penal Code relating to kidnapping and trafficking, besides sections of the Bonded Labour System (Abolition) Act and the Juvenile Justice Act. However, with the girl still untraced, the mother approached the High Court in 2025 seeking directions for her recovery.
Why did the High Court intervene?
While hearing the matter on May 12, the High Court examined the case diary and expressed serious concern over the investigation.
The Bench observed that although the FIR and the statements of several witnesses repeatedly named a woman as the prime suspect, the investigating officers had failed to interrogate her during the crucial early stages of the investigation.
Instead, the police accepted the explanation of the suspect’s family that she had travelled to Ranchi for medical treatment, without verifying the claim through hospital records or any independent inquiry.
The judges described the investigation as lacking urgency, observing that in cases involving missing children, “time is the essence.”
Consequently, the court directed the State government to conduct a fact-finding inquiry into the role of the SPs posted in Gumla between 2018 and 2022, as well as the investigating officers associated with the case.
Why did the DGP seek modification?
The DGP argued that officers posted before February 6, 2020—the date on which the FIR was registered—should not be subjected to the inquiry because they were not responsible for the subsequent investigation.
The State also pointed out that the matter had been taken to the Supreme Court through a Special Leave Petition (SLP). The petition was later withdrawn on June 10, 2026, with liberty to approach the High Court again, following which the modification application was filed.
Why did the High Court reject the plea?
The High Court held that the petitioner’s allegations were not confined to the period after the FIR was registered.
The Bench noted that the mother had specifically alleged in the FIR that she had been visiting the police station for nearly two years before its registration, requesting action to trace her missing daughter.
The court observed that these allegations also require examination and, therefore, the inquiry could not be restricted only to officers posted after February 2020.
Importantly, the Bench clarified that its earlier order had not held any officer guilty.
Instead, it had merely directed the competent authorities to conduct a fact-finding inquiry to determine whether there had been any negligence or dereliction of duty. If lapses are established, appropriate action can then be taken in accordance with law.
Court also questions delay in narco-analysis
The High Court also expressed dissatisfaction over the delay in initiating a narco-analysis test of the prime suspect.
The Bench noted that permission for the test was granted only on June 17, 2026, after repeated monitoring by the High Court. It observed that if such an investigative step was considered necessary, it ought to have been initiated much earlier, and the delay reflected apparent negligence on the part of the investigating agency.
What happens next?
With the modification plea dismissed, the fact-finding inquiry ordered by the High Court will continue.
The court has also directed that the writ petition be listed again on July 9, 2026, for a review of the progress in the investigation.
In its order, the Bench reiterated that the State has a constitutional obligation to protect the life, liberty and dignity of its citizens and that any official apathy in addressing complaints undermines not only fundamental rights but also public confidence in the rule of law.
name the Sps and police officers named in the order
According to the Jharkhand High Court’s order dated May 12, 2026, which is reproduced in the June 18, 2026 order, the following officers were identified for the proposed fact-finding inquiry:
Superintendents of Police (SPs), Gumla
| Name | Period of Posting |
| Anshuman Kumar (IPS) | November 2, 2017 – November 23, 2018 |
| Ashmani Kumar Sinha (IPS) | November 23, 2018 – March 2, 2019 |
| Anjani Kumar Jha (IPS) | March 2, 2019 – April 11, 2020 |
| H.P. Janardhan (IPS) | April 11, 2020 – August 7, 2021 |
| Dr Ehtesham Waquarib (IPS) | August 7, 2021 – September 9, 2023 |
Investigating Officers (IOs)
- Rajesh Kumar Tiwari, Assistant Sub-Inspector (ASI)
- Prem Sagar Singh, Sub-Inspector (SI)
- Ravi Honhaga, Sub-Inspector (SI)
- Aakash Kumar Pandey, Sub-Inspector (SI)
- Mahendra Mahto, Sub-Inspector (SI)
- Rahul Kumar Dasoundhi, Sub-Inspector (SI) — Present Investigating Officer
Current officers who appeared before the High Court
The Bench also recorded the appearance of the following officers during the hearing:
- Haris Bin Zaman, Superintendent of Police, Gumla
- Shruti, SDPO, Campur, Gumla and head of the SIT
- Rahul Kumar Dasoundhi, Present Investigating Officer
The High Court clarified that it has not held any of these officers guilty. It directed the Principal Secretary, Home Department, and the Director General of Police to conduct a fact-finding inquiry to determine whether there was any negligence or dereliction of duty in the handling of the missing minor case.
