MADHYA PRADESH – AUGUST 4 2025 – In a strong indictment of the police and prosecution, the Madhya Pradesh High Court has ordered a departmental inquiry against the Investigating Officer (IO) and other police personnel for planting false witnesses in a 2021 murder case.
The case is titled Nein Singh Dhruve and Others vs The State of Madhya Pradesh.
A Division Bench of Justice Vivek Agarwal and Justice Avanindra Kumar Singh passed the direction while acquitting a father-son duo, Nain Singh Dhruve and Sandeep Kumar Dhurve, who had earlier been convicted by a Mandla trial court and sentenced to life imprisonment.
COURT’S KEY OBSERVATIONS AND DIRECTIVES
The High Court made scathing remarks on the conduct of the police and the public prosecutor in the case, stating:
“Let enquiry be conducted as to what makes them to implant false witnesses to take away life and liberty of innocent citizens and the report be furnished within thirty days thereafter.”
The Court also directed the Director General of Police (DGP) to issue appropriate guidelines for proper investigation by police officers to prevent such incidents in future.
BACKGROUND OF THE CASE: 2021 MURDER OF RAJENDRA
The case pertains to the disappearance and murder of Rajendra in September 2021, whose mutilated body was found with private parts chopped off.
Police claimed Rajendra was murdered by Nain Singh Dhruve and his son Sandeep due to his alleged relationship with Nain Singh’s daughter.
HIGH COURT’S ANALYSIS AND GROUNDS FOR ACQUITTAL
The High Court found major discrepancies in the prosecution’s evidence:
KEY WITNESS WAS PLANTED BY POLICE
The prosecution’s star witness, Chain Singh, was allegedly planted by the police.
“Thus, it is evident Chain Singh (PW-6) is not a witness of last seen or an eye witness. He was planted by the Police for which we shall be ordering a separate enquiry against the I.O. to be conducted by the Senior Police Official for making false accusation and planting false witnesses,” the Court noted.
It further criticized the public prosecutor, stating:
“The prosecution did not re-examine this witness to extract any contradiction on the last statement that he came to know about the incident when Police brought him from Kerala. Thus, it is a gross failure on the part of the concerned Public Prosecutor who conducted the trial.”
CONTRADICTION IN TIMELINE
The postmortem conducted on September 25, 2021, concluded that death had occurred 4–6 days earlier, placing it between September 19–21.
However, prosecution witnesses claimed the victim was in regular contact with the accused’s daughter until September 25.
“Science has yet not so developed to enable a deceased person to connect through mobile phone and talk to daughter of the accused person. This is another lacuna which reveals that how dishonest is the status of investigation in the State of Madhya Pradesh and all the prosecution witnesses including Police officials resorts to lies to just complete investigation and file charge sheet rather than carrying out honest, transparent and independent investigation,” the Court remarked.
OTHER GLARING LAPSES IN THE INVESTIGATION
No DNA test was conducted to confirm the identity of the decomposed body.
The woman, with whom the victim was said to be in a relationship, was never examined to establish motive.
FINAL VERDICT: ACQUITTAL AND RELEASE
The Bench concluded:
“Since the prosecution has failed to complete chain of circumstances and they have stooped down to implant witnesses which erodes the presumption of Police carrying out investigation in good faith, chain of circumstances is not complete and, therefore, impugned judgment of conviction dated 11.12.2023 passed by learned Ist Additional Sessions Judge, Mandla District Mandla, in S.T. No.37 of 2022 is set aside. Appellants be set free immediately if not required in any other offence.”
LEGAL REPRESENTATION
Appellants were represented by Advocate Devendra Kumar Shuka
State of Madhya Pradesh was represented by Government Advocate Ajay Tamrakar
