Introduction:

The Karnataka High Court has recorded an important clarification by the Central Industrial Security Force (CISF) concerning the availability and furnishing of CCTV footage sought by Kannada actress Harshavardhini Ranya Rao in connection with the ongoing gold smuggling case. The development arose in Harshavardhini Ranya Rao v. CISF Commandant & Ors., W.P. No. 18777/2026, before Justice Suraj Govindaraj.

Ranya Rao had approached the High Court seeking access to complete and uninterrupted CCTV footage recording her movements at Kempegowda International Airport during the period surrounding her alleged involvement in the gold smuggling case. The footage sought covered the period from 4:30 PM on March 3, 2025, until 6:00 AM on March 4, 2025.

The dispute before the Court was not about whether CCTV footage had been preserved at all, but about the extent of footage that had actually been furnished to the petitioner pursuant to earlier directions of the High Court. According to the petitioner, although the Court had directed that the relevant footage be made available, only a limited portion covering approximately 4:30 PM to 7:00 PM on March 3 was ultimately handed over to her representative.

The controversy has its background in an earlier petition filed by Ranya Rao, in which the High Court had, on April 2, directed the authorities to provide the CCTV footage sought by her. Subsequently, on July 14, 2026, the Court passed a further order permitting the petitioner or her authorised representative to approach the CISF Commandant at 11:30 AM on July 15, 2026, to collect a copy of the preserved CCTV footage.

When the petitioner’s representative appeared before the CISF Commandant pursuant to that direction, however, the footage supplied was allegedly limited to the period between 4:30 PM and 7:00 PM on March 3. The petitioner contended that this did not comply with the scope of her request, which covered the entire period from 4:30 PM on March 3 to 6:00 AM on March 4.

The petitioner consequently brought the grievance before Justice Suraj Govindaraj. Her case was that the earlier direction of the High Court had not been effectively complied with because the complete footage covering the relevant period had not been furnished.

At the hearing, the Court initially observed orally that if the petitioner was alleging non-compliance with its earlier order, she could avail herself of the remedy of contempt proceedings. This observation arose from the petitioner’s contention that the July 14 direction had not been properly implemented.

The position changed significantly after Additional Solicitor General Arvind Kamath, appearing for the authorities including the CISF, clarified that there had been a misunderstanding regarding the extent of footage to be supplied.

The ASG informed the Court that the CISF had in fact preserved CCTV footage beginning at 4:30 PM on March 3, 2025, and that the recording continued until 11:00 AM on March 4, 2025. According to the authorities, the reason the footage beyond 6:00 AM had not initially been supplied was an internal misunderstanding concerning the earlier court directions. The authorities had understood that the footage was required only up to 6:00 AM and therefore did not furnish the recording extending beyond that period.

The ASG clarified that the entire preserved recording could be supplied to the petitioner, including footage extending up to 11:00 AM on March 4. He further stated that although the original recording had already been erased from the server, a copy of the relevant footage had been preserved and could be reproduced and furnished to the petitioner.

The development is significant because CCTV footage can constitute important contemporaneous material in a criminal investigation, particularly where the movement of an accused or suspect at an airport is relevant to the prosecution case. At the same time, the Court’s order does not determine the evidentiary value of the footage or decide the merits of the gold smuggling allegations against Ranya Rao.

The immediate issue before the Court was narrower: whether the CCTV footage sought by the petitioner had been preserved and whether the authorities were prepared to furnish it in accordance with the Court’s directions.

The ASG’s clarification effectively resolved the immediate dispute over whether the authorities possessed additional footage. Rather than claiming that the requested material did not exist, the CISF acknowledged that a longer recording had been preserved and undertook to furnish it to the petitioner.

Arguments of the Parties:

The petitioner, Harshavardhini Ranya Rao, sought complete and uninterrupted CCTV footage of her movements at Kempegowda International Airport during the relevant period. Her request was for footage commencing at 4:30 PM on March 3, 2025 and continuing until 6:00 AM on March 4, 2025.

The petitioner’s counsel submitted that the earlier directions of the High Court had not been complied with in substance. The counsel explained that pursuant to the July 14 order, the petitioner’s representative appeared before the CISF Commandant on July 15 at the prescribed time to collect the footage. However, the footage handed over covered only the period from approximately 4:30 PM to 7:00 PM on March 3.

According to the petitioner, this was materially narrower than the footage sought and expected to be furnished under the Court’s direction. The petitioner therefore complained that the purpose of the earlier order had not been achieved because a substantial portion of the relevant period remained unavailable to her.

The petitioner’s grievance was particularly significant because the footage concerned her movements during a period relevant to the investigation. The request was not confined to a particular moment or incident but covered a continuous period. From the petitioner’s perspective, a truncated recording could prevent her from examining the sequence of events and could deprive her of potentially relevant material.

Her counsel therefore pressed for access to the footage covering the entire period specified in the petition. The submission was that providing only a few hours of recording could not be treated as meaningful compliance where the request and the Court’s earlier direction contemplated a substantially longer period.

At the hearing, the Court indicated that if the petitioner’s case was that the July 14 order had been deliberately or otherwise not complied with, she could pursue appropriate contempt proceedings. This was a procedural observation rather than a finding that the CISF had wilfully disobeyed the Court.

The petitioner’s side was thus effectively asking the Court to ensure that its earlier direction concerning access to the footage was implemented in its entirety and that the petitioner was not restricted to a limited portion of the relevant recording.

On behalf of the CISF and other authorities, Additional Solicitor General Arvind Kamath clarified that there had been no intention to withhold the footage. He submitted that the authorities had preserved CCTV footage beginning at 4:30 PM on March 3 and that one recording continued until 11:00 AM on March 4.

The ASG explained that the confusion arose because the earlier direction referred to furnishing footage up to 6:00 AM on March 4. The authorities had understood the order as limiting the material to that period and therefore had not initially furnished the longer recording.

The submission was that the CISF had not deliberately withheld the additional footage. Rather, there had been a misunderstanding between the scope of the recording actually preserved and the footage that was required to be furnished pursuant to the Court’s direction.

The ASG further clarified that the authorities were willing to provide whatever material had been preserved. He stated that the original CCTV recording had already been erased from the server, but that the relevant recording had been preserved separately. According to the submission, copies could be prepared from the preserved material and furnished to the petitioner.

The authorities therefore sought to resolve the dispute by making the preserved recording available rather than contesting the petitioner’s entitlement to receive it.

The clarification was significant because it established that the CCTV material did not simply cease to exist after the original server recording was erased. The authorities maintained that the relevant footage had been preserved independently and remained capable of being copied and supplied.

The ASG specifically submitted that if the petitioner approached the first respondent, the preserved recording extending up to 11:00 AM on March 4 would be furnished. This went beyond the petitioner’s originally stated request, which was for footage until 6:00 AM.

Thus, while the petitioner complained of incomplete compliance, the authorities attributed the problem to a misunderstanding regarding the scope of footage to be handed over. The two sides consequently differed less on the existence of the material than on the manner and extent of its furnishing.

The High Court was therefore called upon to consider the immediate procedural issue of access to the preserved CCTV recording rather than determine any disputed factual question concerning the underlying gold smuggling allegations.

Court’s Judgment:

Justice Suraj Govindaraj of the Karnataka High Court recorded the submissions made by both sides and noted the clarification furnished by Additional Solicitor General Arvind Kamath on behalf of the CISF authorities.

At the outset, the Court orally observed that if the petitioner’s grievance was that the earlier order dated July 14 had not been complied with, she could approach the Court through appropriate contempt proceedings. The observation was made in the context of the petitioner’s assertion that the footage furnished on July 15 did not correspond with the extent of material contemplated by the earlier direction.

However, the submission of the ASG provided a clarification that materially addressed the grievance.

The Court recorded that the authorities had preserved a recording beginning at 4:30 PM on March 3, 2025 and extending until 11:00 AM on March 4, 2025. This was considerably longer than the period that the petitioner had originally sought, which ended at 6:00 AM on March 4.

The Court further recorded the ASG’s explanation that the failure to provide the longer footage earlier was the result of a misunderstanding concerning the orders. According to the authorities, since the Court had directed that footage up to 6:00 AM be furnished, the officials had proceeded on the understanding that footage beyond that time was not required.

The Court did not record any finding that the CISF had intentionally withheld evidence. Instead, the order reflects the explanation that the relevant footage had been preserved and that the authorities were prepared to make it available.

The ASG’s assurance that the preserved recording could be copied and furnished was therefore central to the resolution of the immediate controversy. He stated that although the original footage had already been erased from the server, the material had been preserved separately and could be reproduced.

This distinction is important in the context of electronic evidence. The fact that the original server recording has been erased does not necessarily mean that every preserved copy of the footage has ceased to exist. Here, the authorities specifically represented to the Court that the relevant recording had been preserved and remained capable of being copied.

The Court also recorded the assurance that if the petitioner approached the first respondent, the footage available up to 11:00 AM on March 4 would be furnished. Consequently, the material preserved by the authorities extended beyond even the period specifically sought in the petition.

The Court’s order therefore operates primarily as a procedural clarification rather than a determination on the merits of the criminal case. It does not adjudicate whether Ranya Rao committed any offence, whether the footage supports or contradicts the prosecution case, or what evidentiary weight should ultimately be attached to the recording.

Those questions remain matters for the appropriate criminal proceedings. The High Court’s immediate concern was ensuring clarity regarding the material preserved by the CISF and the petitioner’s access to that material pursuant to the Court’s previous directions.

The order also illustrates the importance of precise communication in implementing judicial directions. The dispute arose because the petitioner understood the earlier direction as requiring the relevant period of footage to be furnished, while the authorities had interpreted the direction differently. The ASG’s submission effectively removed that ambiguity by confirming that the longer preserved recording could be provided.

The Court’s earlier observation concerning contempt proceedings must also be understood in its proper procedural context. Contempt jurisdiction ordinarily concerns alleged wilful disobedience of a judicial order. At the stage of the present hearing, however, the authorities explained that the failure to furnish the complete footage was not deliberate but resulted from a misunderstanding regarding the scope of the direction.

The Court therefore had before it an explanation capable of addressing the immediate complaint without necessarily requiring a finding of wilful non-compliance.

The case also raises a broader issue concerning access to potentially relevant electronic material in criminal proceedings. CCTV recordings can provide contemporaneous evidence of a person’s movements, interactions and conduct. Where such footage has been specifically identified and preserved, access to it may be relevant to a person’s ability to understand, challenge or respond to allegations against them.

At the same time, the present order should not be read as establishing an unrestricted right to every piece of CCTV footage held by investigative or security authorities. The entitlement to material would necessarily depend upon the nature of the proceedings, the applicable legal framework, previous judicial directions and considerations concerning investigation, privacy and evidentiary integrity.

In the present case, however, the Court had already issued directions concerning the footage, and the authorities represented that the relevant recording had been preserved. The immediate question was consequently one of compliance and access.

The ASG’s submission that the entire preserved material could be furnished also ensured that the petitioner would receive a recording extending beyond the original requested period. The recording available from 4:30 PM on March 3 until 11:00 AM on March 4 would encompass the petitioner’s requested period ending at 6:00 AM.

The Court accordingly recorded the undertaking and clarification furnished by the authorities. The order reflects that the petitioner could approach the first respondent to obtain the preserved footage.

No final determination was made regarding the merits of the allegations against Ranya Rao. The Court’s proceedings remained confined to the issue of CCTV footage and the implementation of the earlier directions.

The procedural history nevertheless demonstrates how access to electronic evidence can become an important aspect of criminal litigation. When a court directs preservation or production of such material, clarity regarding the precise time period, format and extent of disclosure becomes essential. Any misunderstanding can result in incomplete disclosure and further litigation, as happened in the present matter.

The case also demonstrates the Court’s preference for resolving an apparent compliance issue through clarification where the authorities are willing to provide the material and there is no established finding of deliberate disobedience. Instead of immediately treating the matter as contemptuous conduct, the Court recorded the authorities’ explanation and their willingness to furnish the preserved recording.

The most significant development, therefore, is the confirmation that the CISF has preserved CCTV footage covering a period from 4:30 PM on March 3, 2025 until 11:00 AM on March 4, 2025 and is prepared to provide a copy to the petitioner. The petitioner’s original request for footage until 6:00 AM falls entirely within this preserved period.

The order also ensures that the dispute over the limited footage initially furnished does not prevent the petitioner from obtaining the longer recording. Since the authorities themselves clarified that the preserved material could be copied and supplied, the immediate controversy over its availability was substantially addressed.

Ultimately, the Karnataka High Court’s order is significant less for determining the substantive criminal allegations and more for reinforcing the importance of access to preserved electronic evidence and faithful implementation of judicial directions. The Court has ensured that the petitioner is not left with only the limited footage initially supplied when the authorities themselves acknowledge that a substantially longer recording has been preserved.

The matter thus illustrates a practical aspect of criminal procedure: evidence may be decisive not merely because it exists, but because timely preservation, proper disclosure and meaningful access determine whether a party can effectively use it. In the present case, the clarification before the High Court has paved the way for the petitioner to obtain the preserved CCTV footage covering the relevant period and even extending several hours beyond it.