Custodial deaths represent one of the most serious violations of human rights and constitutional governance in India because they occur when an individual is under the protection and control of the State. Such incidents raise important questions regarding the accountability of law enforcement agencies, the protection of fundamental rights and the effectiveness of compensation as a constitutional remedy. The concept of compensation jurisprudence has developed significantly through judicial interpretation, particularly under Article 21 of the Constitution of India, which guarantees the right to life and personal liberty. The Supreme Court of India has recognized that monetary compensation may be awarded under public law where State authorities violate fundamental rights through custodial torture, illegal detention or custodial death. This principle has transformed compensation from a private law remedy into an important constitutional mechanism for enforcing human rights and ensuring State accountability. 

The present study examines the evolution and application of compensation jurisprudence in custodial death cases with particular reference to the State of Gujarat. It analyses the constitutional and statutory framework, judicial precedents and the role of institutions such as the National Human Rights Commission [NHRC] and the Gujarat State Human Rights Commission [GSHRC] in protecting the rights of detainees and recommending compensation. The paper also evaluates recent developments in policing, forensic investigation and human rights protection in Gujarat while identifying practical challenges relating to investigation, accountability and implementation of judicial directions. The study adopts a socio-legal approach by examining not only the legal principles governing compensation but also the social realities affecting victims and their families. It concludes that although Indian constitutional jurisprudence has considerably strengthened the right to compensation in custodial death cases, effective implementation requires institutional transparency, prompt investigation, independent oversight and sustained commitment to constitutional values and human dignity.