ILLUSTRATIVE CASES 16.8 The substantial increase in the number of cases considered by the Commission is reflected in the range of human rights violations brought before it. As in the previous years, a targe number of cases related to custodial deaths and torture, illegal arrests and detention, negligence in the performance of duties by pubic servants leading to violation of human rights. The Commission has also considered cases which affect human dignity, rights of children, women, minority groups and disadvantaged communities particularly Dalits and Tribals. RATIONALE FOR GRANT OF IMMEDIATE INTERIM RELIEF1 COMPENSATORY JURISPRUDENCE Policemen turn robburs and kill Innocent eltJrens ( m e No. 144193-94INHRC1 The Commission received a complaint from one Rita Dhawan that the Maruti van of her husband, while returning from Varanasi, was surrounded by six policemen, near the Police Station Civil Lines, Ranchi, who demanded Rs. one lakh and, on being refused, shot at the petitioner's husband and others in the van from point blank range and killed him. They also removed the gold chain, rings and wrist watch from the body of the deceased. .Onnotice from the Commission, the Under Secretary, Govt. of Bihar submitted a report stating that the SHO of the police station on 5 December 1993, on receiving information that some criminals were absconding in the said van, followed the van alongwith other police staff and as the persons in the van were firing recklessly, police returned the fire and as a result three of those in the van were killed. A report was lodged about the incident, the police officers were suspended and a case under Section 302/379/201131 IPC was registered against the SHO and others. The accused persons were arrested and the case was under trial in the Court of the Session Judge, Gays-The trial ended in a conviotion and several persons were sentenced to the extreme penalty of law. But the Commission decided not to close the case and issued notice to the Chief Secretary, Govt. of Bihar, as to why, in the circumstances of the case, Smt. Rita Dhawan should not be awarded an 'immediate interim relief of Rs. 10 lakhs without prejudice to her private law rights for damages. 'The State Government responded contending that as the accused persons had already been convicted and sentenced to death, the Government found no justification for paying a sum of Rs.10 Lakhs as compensation and that it would cause unnecessary financial burden on the State. In the Commission's analysis, the stand taken by the State Government seemed to have proceeded on the assumption that the establishment of culpability of public servants at a criminal trial and their conviction and sentence puts at rest even the claim for compensation or immediate interim relieft to the dependents of the victim envisaged in Section 18 (3) of the