Shreya Gupta
On 30th July, 2025, the Madhya Pradesh High Court acquitted a father-son duo in a 2021 murder case and directed the State Director General of Police (DGP) to initiate a departmental inquiry against the Investigating Officer (IO) and other police personnel involved. The Division Bench comprising Justice Vivek Agarwal and Justice Avanindra Kumar Singh passed the order in the case of Nein Singh Dhruve and Others vs The State of Madhya Pradesh, highlighting serious lapses and misconduct in the police investigation.
The case concerned the death of a man named Rajendra, who had gone missing in September 2021 and was later found dead, his body mutilated. The police arrested Nain Singh Dhruve and his son Sandeep Kumar Dhruve, alleging that they murdered Rajendra because he was in a relationship with Nain Singh’s daughter. A Mandla trial court convicted them in 2023 and sentenced them to life imprisonment.
However, upon appeal, the High Court found glaring flaws in the prosecution’s case. One of the key issues identified was the role of the prosecution’s star witness, Chain Singh. Though he initially claimed to have witnessed the crime while staying at the accused’s house, during cross-examination, it was revealed that he had been in Kerala during the relevant time and was brought back by the police only later. The Court concluded that Chain Singh had been planted by the police, which constituted a serious miscarriage of justice. The prosecution also failed to re-examine him to counter his later testimony, which the Court attributed to negligence on the part of the Public Prosecutor.
The Court also highlighted contradictions in the prosecution’s narrative. The postmortem report indicated that the victim had died 4-6 days before the body was discovered on September 25, 2021. However, prosecution witnesses claimed that the victim was in regular contact with the accused’s daughter between September 19 and 25. The Court sarcastically remarked that science had not yet advanced to allow a deceased person to speak on the phone, underscoring the absurdity and dishonesty in the investigation.
Moreover, the High Court noted that no DNA test was conducted to confirm the identity of the decomposed body, and the woman alleged to be the victim’s partner was not examined to establish motive, further weakening the prosecution’s case. The Court found that the police were more focused on closing the case than conducting a fair and thorough investigation. It lamented the dishonest and unprofessional state of investigations in Madhya Pradesh, stating that the practice of planting witnesses eroded the presumption that police act in good faith.
As a result, the Court set aside the conviction delivered by the trial court on December 11, 2023, and ordered the immediate release of the appellants unless required in any other case. Additionally, it directed the DGP to conduct a departmental inquiry and issue new guidelines to ensure proper police investigations in the future.
Click here to access the order
Case Title: Nein Singh Dhruve and Others vs The State of Madhya Pradesh
Bench: Justice Vivek Agarwal and Justice Avanindra Kumar Singh
Case Number: CRIMINAL APPEAL No. 306 of 2024
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