The Jharkhand High Court, in *Md. Mumtaz Ansari v. State of Jharkhand*, held that inquiries into custodial deaths, custodial disappearances, and custodial rape must mandatorily be conducted by Judicial Magistrates under Section 176(1-A) CrPC and Section 196(2) BNSS. The Court was hearing a PIL highlighting that 427 custodial deaths had occurred in Jharkhand since 2018 and that authorities were routinely appointing Executive Magistrates instead of Judicial Magistrates for inquiries. The Court observed that custodial violence is a serious violation of Article 21 and described it as an affront to justice. It held that the statutory use of the word “shall” makes judicial inquiry mandatory and that Executive Magistrates cannot substitute Judicial Magistrates. Noting systemic non-compliance and discrepancies in official records, the Court directed fresh judicial inquiries in improperly handled cases and ordered strict compliance with future reporting and inquiry requirements.