The Supreme Court of India has upheld the conviction in the murder case affirming the concurrent findings of the Trial Court and the High Court of Madhya Pradesh. The Court ruled that the chain of circumstantial evidence was complete and unbroken, leaving no reasonable ground to doubt the appellant’s guilt.
The Bench of Justice Prashant Kumar Mishra and Justice Vipul M. Pancholi has observed that the prosecution had established an “unbroken chain of circumstances,” the Supreme Court held that no other reasonable inference was possible except that the appellant committed the murder.
The case traces back to July 2009, when Archana @ Pinki went missing from Indore. A missing report was lodged by her mother on July 28, 2009. During the investigation, it emerged that ransom calls demanding ₹5 lakh were made to her husband from her own mobile phone.
Subsequently, the deceased’s mobile phone was traced to third parties who disclosed that they had purchased it from the appellant. Acting on a memorandum statement made by the appellant under Section 27 of the Indian Evidence Act, the police recovered the deceased’s body from a well near the Indore bypass.
The Trial Court convicted the appellant for murder and destruction of evidence. The High Court dismissed his appeal in 2023, leading to the present appeal before the apex court.
The Supreme Court reiterated the well-settled principles governing conviction based on circumstantial evidence as laid down in Sharad Birdhichand Sarda v. State of Maharashtra. The Court emphasized that the chain of circumstances must be so complete that it excludes every hypothesis except the guilt of the accused.
The Bench held that in the present case, the prosecution successfully established the deceased’s disappearance and timely missing report. Ransom calls made from her mobile phone. The appellant’s possession and sale of the deceased’s phone. Recovery of the dead body at the appellant’s instance under Section 27. Recovery of the deceased’s scooty at his disclosure. Medical evidence confirming homicidal death by ligature strangulation.
A major pillar of the prosecution case was the recovery of the dead body pursuant to the appellant’s disclosure statement. The Court elaborated on the scope of Section 27 of the Evidence Act, relying on precedents including Udai Bhan v. State of Uttar Pradesh, Bodhraj v. State of Jammu and Kashmir, and Pulukuri Kottayya v. King Emperor
The Court reiterated that “discovery of fact” includes not merely the object recovered but also the place of recovery and the accused’s knowledge of its existence. The recovery of the body from a specific well, based on the appellant’s statement while in custody, was held to be a strong incriminating circumstance.
Rejecting the defence argument that the absence of DNA testing weakened the prosecution’s case, the Court held that identification by close relatives and corroborating witnesses was sufficient. The medical evidence confirmed that the body, though partially decomposed, retained identifiable features. The post-mortem established death by throttling and ligature strangulation, confirming homicidal death.
While the prosecution alleged that the appellant murdered the deceased to avoid sharing ransom money, the Court clarified that proof of motive is not indispensable when other circumstances conclusively establish guilt. The Bench referred to Mulakh Raj v. Satish Kumar, reiterating that absence of proved motive does not break the chain of circumstantial evidence.
Accordingly, the appeal was dismissed. However, noting that the appellant has undergone more than 15 years of imprisonment, the Court granted liberty to apply for remission in accordance with the applicable state policy.
Case Details
Case Title: Neelu @ Nilesh Koshti Versus State of MP
Citation: JURISHOUR-68-SC-2026
Case No.: CRIMINAL APPEAL NO.5357 OF 2025
Date: 23/02/2026
