Who Is IPS Manish Agrawal? Rajasthan High Court Rejects Child Custody Plea, Officer’s Career Back in Spotlight Amid Adoption Dispute
Senior IPS officer Manish Agrawal has once again found himself at the centre of public attention after the Rajasthan High Court dismissed a habeas corpus petition filed by the biological parents of a four-year-old boy seeking his custody. While the case has generated widespread discussion because of the child custody dispute, the High Court made it clear that the legality of the alleged adoption cannot be decided in habeas corpus proceedings and must instead be examined by a competent civil court after considering evidence from both sides.
The judgment has also revived interest in the career of Manish Agrawal, a 2010-batch IPS officer currently serving in the Rajasthan cadre. His professional journey has been eventful, marked by an inter-cadre transfer from the erstwhile Jammu and Kashmir cadre, high-profile field postings, a corruption investigation, suspension, reinstatement and now a legal battle involving child custody.
Rajasthan High Court Declines to Interfere with Child’s Present Custody
The order was delivered by a Division Bench comprising Justice Inderjeet Singh and Justice Bhuwan Goyal, which dismissed the habeas corpus petition filed by Agra residents Sidharth Gupta and Sakshi Gupta.
The petitioners had approached the High Court seeking custody of their four-year-old son from IPS officer Manish Agrawal and his wife, Sharmistha Gupta. They alleged that the child was being wrongfully retained despite having been handed over only for a temporary period.
After hearing both parties, the High Court concluded that the present custody of the child could not be described as illegal. The Bench observed that the child had initially been entrusted voluntarily to the respondents. Since illegal detention is an essential condition for invoking habeas corpus jurisdiction, the petition was found to be legally untenable.
The judges also noted that the child has now settled in Jaipur, is studying in school and has become part of his present family environment. At this stage, the Court felt that disturbing his custody would not serve his welfare, which remains the foremost consideration in such matters.
However, the Bench clarified that its observations were confined only to the maintainability of the habeas corpus petition. It specifically stated that the legality and validity of the alleged adoption involve disputed questions of fact that require documentary as well as oral evidence. Such issues, the Court said, can only be adjudicated by a competent civil court through appropriate legal proceedings.
How the Custody Dispute Reached the High Court
According to the petition filed by the biological parents, they had entrusted their young son to Sharmistha Gupta, who is the petitioner’s sister and the wife of IPS officer Manish Agrawal, for a period of only 20 days.
The petition claimed that the temporary arrangement was made because Sharmistha was undergoing IVF treatment. The biological parents alleged that psychologists had suggested spending time with a child as a supportive measure during the treatment process.
They contended that after the agreed period ended, the couple refused to return the child. According to them, the respondents later claimed that the boy had already been legally adopted.
The petitioners challenged this claim before the High Court, arguing that no valid adoption ceremony had taken place and that there was no legally sustainable documentation to establish a lawful adoption.
Their counsel also questioned the timeline presented by the respondents. According to the petitioners, the alleged adoption ceremony was said to have taken place on May 8, 2025, while the child reportedly began residing with the respondents only in December 2025. They argued that the sequence itself raised serious questions regarding the validity of the adoption claim.
Relying upon the provisions of the Hindu Minority and Guardianship Act, 1956, they maintained that they continued to be the child’s lawful guardians and sought restoration of custody.
IPS Officer’s Defence Before the Court
Appearing for IPS officer Manish Agrawal and his wife, senior counsel strongly contested the allegations made by the biological parents.
The respondents submitted that the child had been legally adopted on May 8, 2025, in accordance with the provisions of the Hindu Adoptions and Maintenance Act, 1956.
They informed the Court that the biological parents had consented to the adoption over the telephone and that all legal requirements under the applicable law had been duly complied with.
The defence also argued that the child has since become well settled in Jaipur. He is studying in a reputed private school, receiving proper education, care and affection, and has comfortably adjusted to his present surroundings.
Counsel further argued that the validity of an adoption cannot be examined in habeas corpus proceedings, which are limited to determining whether custody is illegal. Since the dispute requires detailed examination of evidence and witnesses, the matter should appropriately be decided by a civil court.
Welfare of the Child Remains the Primary Consideration
While dismissing the petition, the Rajasthan High Court reiterated that the welfare of the child must always remain the paramount consideration in custody-related matters.
The Bench observed that the child is presently residing in a stable environment in Jaipur and there is nothing to indicate that he is under illegal confinement.
Considering these circumstances, the Court held that immediate transfer of custody would not be in the child’s best interest.
At the same time, the Court left the door open for both parties to pursue appropriate civil proceedings to determine whether the alleged adoption satisfies the legal requirements prescribed under law.
Until such proceedings are concluded, the present custody of the child with Manish Agrawal and his wife will continue.
Who Is IPS Officer Manish Agrawal?
Manish Agrawal is a 2010-batch Indian Police Service officer presently serving in the Rajasthan cadre. He currently holds the position of Superintendent of Police (Rules) at the Police Headquarters in Jaipur.
Although he now serves in Rajasthan, his journey in the IPS began in the erstwhile Jammu and Kashmir cadre, where he received his initial cadre allocation after clearing the UPSC Civil Services Examination.
Originally from Uttar Pradesh, Agrawal completed a Bachelor of Arts degree before entering the civil services as a direct recruit. He officially joined the Indian Police Service on August 30, 2010.
Inter-Cadre Transfer to Rajasthan
During the early phase of his career, Agrawal served in Jammu and Kashmir after completing his police training.
In March 2014, he obtained an inter-cadre transfer to Rajasthan on matrimonial grounds following his marriage to a 2012-batch Rajasthan cadre IPS officer.
The transfer was approved under the existing policy governing inter-cadre transfers based on marriage. However, the marriage later ended in divorce.
Following his move to Rajasthan, Agrawal held several important field assignments and served as Superintendent of Police in districts including Barmer and Dausa. During these postings, he handled a range of policing responsibilities involving law and order, crime control and district administration.
Earlier Vigilance Inquiry in Jammu and Kashmir
During his tenure in the erstwhile Jammu and Kashmir cadre, Agrawal reportedly came under the scanner of vigilance authorities over allegations relating to a bribery complaint connected with the investigation of a suicide case.
However, no prosecution ultimately followed, reportedly because the required sanction for prosecution was not granted.
The 2021 Rajasthan Anti-Corruption Bureau Case
The biggest controversy in Agrawal’s career emerged in 2021 when the Rajasthan Anti-Corruption Bureau registered a corruption case linked to alleged bribery in connection with the Bharatmala and Delhi-Mumbai Expressway project.
According to investigators, certain officials and middlemen allegedly demanded illegal gratification from a construction company associated with the infrastructure project.
The ACB arrested Manish Agrawal on February 2, 2021. Following his arrest under provisions of the Prevention of Corruption Act, he remained in judicial custody for nearly eight months before obtaining bail.
His arrest resulted in his suspension from service while the investigation continued.
Return to Active Service
After remaining under suspension for more than three years, the Rajasthan Government revoked the suspension in 2024, allowing Agrawal to resume official duties.
He was subsequently posted as Superintendent of Police (Rules) at the Police Headquarters in Jaipur, where he continues to serve.
Fresh Spotlight Following High Court Order
The Rajasthan High Court’s latest ruling has once again brought IPS officer Manish Agrawal into the national spotlight.
While the Court has declined to interfere with the child’s present custody, it has deliberately refrained from deciding the legality of the alleged adoption. Instead, it has made it clear that this issue involves disputed facts that can only be settled after a full-fledged trial before a competent civil court.
For now, the child will continue to remain with Manish Agrawal and his wife. The next chapter of the dispute is likely to unfold before the civil court, where both sides will have the opportunity to present documentary evidence, witness testimony and legal arguments to establish their respective claims regarding the adoption.
