The Supreme Court upheld a Karnataka rule allowing complainants to approach Human Rights Courts directly, without first exhausting remedies before the State Human Rights Commission. The Court clarified that the Protection of Human Rights Act, 1993 does not mandate prior recourse to the Commission before invoking the jurisdiction of a Human Rights Court. This ruling reinforces the independent statutory character of Human Rights Courts established under Section 30 of the Act, expanding direct access to judicial remedies for rights violations.

Human Rights Courts are established under Section 30 of the Protection of Human Rights Act, 1993 (PHRA). Each state government is empowered to specify, by notification, a Court of Session in each district to be a Human Rights Court for speedy trial of offences under the Act. The question before the Supreme Court was whether a complainant must first approach the State Human Rights Commission (SHRC) — and exhaust that remedy — before directly petitioning a Human Rights Court.

The Court held that no such mandatory sequencing exists under the PHRA. The Act creates parallel, independent channels: the National Human Rights Commission (NHRC), SHRCs, and Human Rights Courts are distinct forums. The PHRA does not contain any provision requiring exhaustion of commission-level remedies as a precondition to approaching a Human Rights Court.

This ruling is constitutionally significant because it reinforces Article 21 (right to life and personal liberty) by ensuring that procedural barriers do not delay access to judicial remedies in human rights cases. It also touches Article 14's guarantee of equality before law — arbitrary gatekeeping that delays justice for victims would violate this guarantee.

The Karnataka rule permitting direct access was therefore upheld as consistent with the PHRA's scheme. Practically, this means victims of human rights violations — especially those involving police excesses, custodial deaths, or denial of fundamental freedoms — need not wait for commission proceedings to conclude before approaching a Human Rights Court.