Erandaka and Another v. Halwela, Officer-In-Charge, Police Station, Hakmana and Others – sllr 2004 volume 1 page 268
In the case between the petitioners (two brothers) and respondents including the 2nd and 3rd respondents (police officers) and the 7th respondent (prison officer), the court addressed the issue of whether the petitioners’ fundamental rights under Article 11 of the Constitution were violated through alleged assaults while in police and remand custody. The court determined that, although individual criminal liability for the alleged ill-treatment could not be conclusively attributed to any specific police or prison officer, the evidence, including medical reports, sufficiently established that the petitioners were subjected to cruel, inhuman, or degrading treatment while in State custody. State liability for constitutional violations was reaffirmed, even in the absence of individual officer

