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Neelu @ Nilesh Koshti v. The State of Madhya Pradesh

Criminal Appeal · 2026 INSC 173Decided 20 Feb 2026
Crl.A. No.-005357-005357 - 2025
Justice Prashant Kumar Mishra · Justice Vipul M. Pancholi · Justice N.V. Anjaria

Background

A woman, Archana @ Pinki, went missing in Indore in July 2009; her husband received ransom calls of Rs.5 lakh from her own mobile number, and the phone was later traced to the appellant, who had sold it. Acting on the appellant's disclosure statement to police, investigators recovered the victim's body from a well and her scooter from a parking stand. The trial court convicted the appellant of murder and destruction of evidence based entirely on circumstantial evidence, and the Madhya Pradesh High Court upheld the conviction, leading to this final appeal to the Supreme Court.

Decision Breakdown

The Supreme Court applied the classic five-point test for circumstantial evidence convictions from Sharad Birdhichand Sarda v. State of Maharashtra, examining each link in the prosecution's chain: the missing report, the ransom calls traced to the victim's phone, the appellant's possession and sale of her phone, the recovery of her body and scooter based on his disclosure statement (admissible under Section 27 of the Evidence Act), identification of the decomposed body by relatives who recognized her clothing and face, and medical evidence confirming homicidal strangulation. Rejecting defence arguments about delay in the missing report and absence of DNA testing, the Court found the chain of circumstances complete, unbroken, and pointing irresistibly to the appellant's guilt, and dismissed the appeal, upholding the life sentence, though it granted him liberty to apply for remission given he had already served over 15 years in custody.

Lesson Learnt

A murder conviction can validly rest entirely on circumstantial evidence (recoveries made from an accused's own disclosure statement, phone/asset trails, and medical corroboration) provided every link in the chain is proved and, together, excludes every reasonable possibility except the accused's guilt; minor gaps like absence of DNA testing or a short delay in filing a missing report do not by themselves defeat an otherwise complete chain.

Official source (sci.gov.in)View Judgment (PDF)

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