34 : CtVtL LtBERTIES Commission recommends that all of these areas, too, receive the increased attention of the State Governments. 4,32 As deaths resulting from custodial torture in prisons has been found to be comparatively rare, the Commission in December 2001modified its earlier guidelines requiring the videography of post-mortem examinations of custodial death occurring in jails. While the video-filming of post mortem examinations of all deaths occurring in police custody was to continue as before, this requirement was relaxed in regard to deaths occurringin judicial custody. In the latter cases, it was deemed to be necessary only when the preliminary inquest by a magistrate raised the suspicion of foul play, or where a complaint alleging foul play was made to the concerned authorities, or some other reason arose giving rise to a suspicion of foul play. ^C] Encounter Deaths 4.33 The guidelines of the Commission in respect of the procedures to be followed by State Governments in dealing with deaths occurring in encounters with the police were circulated to all Chief Secretaries of States and Administrators of Union Territories on 29 March 1997. The Commission called for the acceptance of these guidelines and their faithful implementation. Letters were thereafter received from all State Governments/Union Territories conveying their acceptance of the guidelines. 4.34 During the course of the year 2001-02, the Commission received 58 communications from various State Governments in respect of police encounters. The details are mentioned in Annexure 8(a). The Commission also received a total of 113 complaints from sources other than State Governments in respect of deaths that had allegedly occurred as a result of fake encounters. The largest number i.e. 74 were received from Utter Pradesh. The details are given in Annexure 8(b). In addition, the Commission also received 78 complaints, in respect of deaths in police firing as reflected in Annexure 8(c). 4.35 The allegation of an extra-judicial killing resulting from a 'fake' encounter is an extremely grave one. In respect of each of these complaints, therefore, the Commission has sought to ensure that enquiries were instituted and action taken in accordance with its gmdelines. In all such cases, too, the Commission continues to monitor developments until it is satisfied that justice has been done. NATIONAL HUMAN RIGHTS COMMISSION