Drafting Test (IA 2) – Factual Matrix

Crux

Riana is 29-year-old female actor who has been predominantly active in Hindi movies. While she has
been acting since 2015, it is only from 2019 that she started getting recognized for her performances on
screen. However, some of her promising movies released in 2022 and 2023, both in the theatres and
OTT platforms, failed to garner positive reception. Nonetheless, she did have one decent hit movie
‘Tango’ among other flops. Thereafter, she took a break from acting in movies, at least it seemed so.
There was also news breaking out that she had backed out of some movies she had committed in
principle and moved out of other ongoing negotiations with certain top production houses. News had
spread during the end of 2023 and early 2024 that the industry has not taken her actions positively.
Director VasuN, one of the directors from whose movie Riana had backed out, was reported by
Bollywood News Prime (an entertainment media house) in December 2024 to have said that “Riana
will not act anymore in my movies, and she must be taught a serious lesson”. Anyway, as expected
Riana did not have any releases in 2024 and presumably even for 2025. In 2024, she nevertheless acted
in some advertisements though she did not attend any interviews and media shows. Her Instagram page
during this period showed that she was spending most of the time with family and engaging in
meditation sessions and physical activities.

However, to the shock of her family and followers, on the morning of 15 January 2025, Riana was
found dead in her apartment (D-10, Maya Villa Society) in a posh locality of Bandra, around 5-6 kms
away from the famous GC Shinde Govt Hospital in Mumbai. She was found hanging from the fan
above the cot in her bedroom. Her family suspected foul play by unidentified entities from the industry
and immediately lodged a complaint with the police. In the information, while the family did not
indicate anything else suspicious that Riana told them in the last few days, they reported the fact a
week before, Riana had told them she was getting constant calls and SMSs that were cryptic yet
bullying from certain unknown phone numbers. The police recorded such information as FIR
No.55/2025 in the afternoon. Thereafter, they investigated the case. Ultimately, on 10 February 2025,
the police filed a Report u/s 189 r/w Sec 193 BNSS before the jurisdictional Judicial Magistrate First
Class (JMFC) in Bandra East concluding that Riana’s death was caused by suicide and there was no
scope for murder by anyone.

Investigation post-FIR

Immediately after filing the FIR on January 15, the Police promptly visited the scene of incident –
Riana’s apartment – and examined the crime scene. When the police reached there, several individuals
had gathered outside the apartment – Riana’s house-help, some Fans Association members, her friends
like Inzaria, Renuka, James, Parvathi, and Zohain, apart from some industry colleagues like Radhika
Sanon and Khureshi-Abraam. Upon examination of the scene, the police found the following items
around the bedroom: the thick 20 mm white rope used for hanging, ruffled up bedsheet, a pillow lying
on the ground near the bedroom door. On top of the bedroom’s chest of drawers, the Police spotted
Riana’s phone, her purse, a medical prescription, and the bottle of tablets prescribed in it, along with
other regular items such as pen, paper, her water bottle (half-full) and an empty notepad that was fresh
out of the packet. One of the almirahs in her bedroom was also found partially open at the time of the
Police’s first visit. After examination in the presence of an independent witness, the Police seized some
of these items and prepared a seizure panchnama. The memo prepared u/s 103(5) BNSS during this
examination and that was submitted before the Magistrate listed that the following items were seized
and later subjected to investigation, forensic examination, and preserved for trial:- victim’s purse, bank
statements, passbook, phone directory and calendar, bedsheets, 20mm rope, victim’s dress samples, and
her water bottle. Note that the list of items seized and submitted as evidence remained the same even at
the end of the investigation except otherwise mentioned later in this matrix.

As the next step in the investigation, the Police took Riana’s corpus to the DMRC Bandra West
Government Hospital, located 10-11 kms away from Riana’s home, for the purpose of post-mortem
procedures. The concerned doctor and their team submitted their autopsy report on January 21. The
report mainly rested upon the following four observations: a) Asphyxiation due to hanging was the
primary cause of Riana’s death; b) Definite marks of the tightened 20 mm rope on the neck and that
portion of the neck were found to be blue in color due to the clotting of blood; c) Victim’s blood
samples had strains of a medicine that had a few salts that are also generally found in some anti-
depressant medicines used for clinical depression conditions; and d) Approximate time of death was
calculated as being between 2:40AM and 3:20AM. Upon completion of investigation, the Police
submitted this autopsy report along with other relevant documents and things to the Magistrate. The
Police Report submitted on February 10 primarily relied on the autopsy report to claim that Riana was
undergoing depression and concluded her death as a case of suicide triggered by such mental condition.

Since the afternoon of January 15, the police have been interrogating individuals who may have some
acquaintance with the facts of the case u/s 180 BNSS. They interviewed some neighbors in Riana’s
locality to see if they had seen or heard anything suspicious the night before or early morning on the
date of incident. The police also questioned the house-help at Riana’s house as well as the actor’s
driver apart from close family members. Later, on February 1, Ram Kishore 1 appeared on a news
channel and gave a brief interview and revealed there were a few visible injury marks on Riana’s
forearms, upper back and shoulders. When the media asked the Circle Inspector Vikram Singh 2 about
Kishore’s revelation, the officer briefly responded: “You see, hmm… we are trying our best to
investigate this alright…uh...we will…will look into it…”.

Riana’s mother was in distress and shock after the incident and was confined to her house in Worli.
However, Riana’s father and younger sister were worryingly eager, and they were constantly talking to
Riana’s friends as well as her neighbors to fetch more relevant details. On January 25, Riana’s sister
happened to meet Riana’s school friends (Renuka and Zohain), who were still her best friends and
staying in Mumbai. The sister asked them about the medicines found in her bedroom. Renuka

1
One of the attendants working at the mortuary department of the DMRC Hospital.
2
The Investigating Officer (IO) in this case.
2
remarked: “Riana was taking those medicines just for the last two weeks in order to be able to sleep at
night as she was not able to do so naturally due to some new kinda food diet she had been following
since 10 December 2024”. On a different day, Rekha D’Souza3 visited Riana’s parents in Worli to
convey condolences. During the conversation, Rekha mentioned that on January 17, the Police had
interrogated her briefly and she had told everything she knew about the case and had heard during that
fateful early morning of January 15. She told the police had taken down her statement though she did
not get a chance to read or sign the statement. Further, Rekha also conveyed that during her
interrogation, she had appraised the police about the CCTV camera in her car porch which had an angle
that covered the view towards the society gate and portions of the only road that connects the main gate
and other houses in the D block. The Police had told her they would fetch the camera footage later
when and if deemed necessary.

Annexure 1 - List of witnesses and their Sec 161 statements produced before the Magistrate:

1. Iqbal Azadullah – resident of D-9, Maya Villa Society – statement reported that he did not hear
anything that morning as he was fast asleep after a long journey back from Europe the day before.
2. Joseph Alex-Nariman – resident of D-8, Maya Villa Society – statement revealed he was out of
station that day and was in New Delhi for a business meeting. However, Nariman revealed that on
January 3, a few people had come in two cars to Riana’s home, and they were seen talking to her at
the doorstep of the house and that Riana looked bothered during that conversation. Nariman’s
house was diagonally opposite Riana’s.
3. Rohith Kohli – resident of D-11, Maya Villa Society – statement revealed he couldn’t hear anything
suspicious on that night or early morning.
4. Rekha D’Souza – resident of D-6, Maya Villa Society – Rekha’s house is closest to the main gate
of the society and any vehicle that must reach D-10 would have to go past her house. Apart from
this, the statement only indicated she may have heard some distant noise of a car revving quickly
and moving away on the road around 3:35–3:40AM when she had woken up briefly to take her
medicines for flu.
5. Roopa Devi – Riana’s house-help who has been serving her for the last five years. She was the first
one who saw Riana hanging on the fan when she came for daily chores on January 15 at 6:30AM.
The statement revealed that immediately, she called Riana’s family and informed them.
6. Mother, father, and sister of Riana – their statements were recorded between 4PM and 5PM on
January 15, before any of the other mentioned witnesses except Roopa Devi. Their statements were
mostly the repetition about their interaction with Riana in the last few weeks before her death and
other points already provided in the FIR.

Annexure 2 - Only other evidentiary objects the police produced before the Magistrate beyond the
ones in the seizure panchnama and their respective forensic or other examination reports:

1. The bottle of tablets found on top of the chest of drawers in Riana’s bedroom; and
3
One of Riana’s neighbors who lived a few blocks away from her in the Maya Villa Society.
3
2. The medical prescription for that medicine.
Your Relevance

Riana's family is not satisfied with the police investigation and the final report filed u/s 193 BNSS.
Hence, her father and sister have approached you for legal advice and action. As the advocates with the
vakalatnama for the aggrieved, identify the most specific legal remedy in this scenario and draft a
suitable application/petition/complaint to be filed before the appropriate court or other authorities, if
any. In your draft, make sure to highlight the specific prayer(s) you would submit before the court.