A second man appeared in court today on suspicion of drugging, raping and murdering British teenager Scarlett Keeling found dead on a beach in Goa.
Placido Carvalho, understood to be in his late 40s, was remanded in custody for 14 days.
Carvalho, who was arrested last night by Goan police, has not yet had any charges laid against him, said BBC News.
Meanwhile a third person was arrested earlier today in connection with 15-year-old Scarlett's death, according to Vikram Varma, the lawyer acting for her mother Fiona MacKeown.
Police are already questioning the first man they arrested, Samson D'Souza, 28, who appeared in court in Mapusa, Goa, on Monday and was remanded in custody for 14 days.
Mr Varma said there will be further arrests in connection with Scarlett's death.
"I have been told the police will be arresting more people," Mr Varma said from Goa today.
Local police initially said Scarlett, whose semi-naked body was found in the resort of Anjuna on February 19, had accidentally drowned.
A murder investigation was launched following a second post mortem examination - carried out following pressure from Ms MacKeown - which showed she had been attacked.
Scarlett had been staying with her boyfriend, a 25-year-old Goan tour guide, called Julio Lobo, in Anjuna, when she was last seen at a bar in the resort.
In a letter to Indian Prime Minister Manmohan Singh, Ms MacKeown said: "I have no faith in the leadership of the Goa Police."
She has claimed drug dealers, politicians and police had collaborated to disguise her daughter's death and said the administration tried to it hush up as a simple case of drowning.
Mr Varma said his client wanted to know why the killing was reported as a drowning case.
He said criminals had influence over the police administration to ensure such crimes were reported as death due to drowning or overdose.
Meanwhile police inspector Kishan Kumar has said Ms MacKeown could still be investigated for leaving her daughter at the resort while the rest of the family travelled.
Mr Kumar said all aspects of the case will be looked at and added that could include possible neglect.
Ms MacKeown said: "I think I was probably naive and too trusting of the people around her that claimed to be her friends.
"I do not think I was negligent in any other way."
Ms MacKeown was on a six month holiday with her boyfriend, Scarlett and six other younger children.