MP High Court Acquits Murder Convict After Finding Trial Court Misread FSL Report and Left Circumstantial Chain Incomplete

The Madhya Pradesh High Court at Jabalpur set aside a life sentence under IPC Section 302 and the SC/ST Atrocities Act, finding the trial court had erroneously recorded blood evidence and relied on broken circumstantial links.

A Division Bench of the High Court of Madhya Pradesh at Jabalpur, comprising Justice Vivek Agarwal and Justice Avanindra Kumar Singh, acquitted Lotan Lodhi alias Nanna of murder and related charges on 2 September 2026, setting aside a life sentence awarded by the Special Judge, SC/ST (Prevention of Atrocities) Act, District Damoh. The trial court's judgment dated 31 October 2025, in SCATR No. 64/2024, had convicted Lodhi under Section 302 of the Indian Penal Code, 1860 and Section 3(2)(v) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989. The High Court found that the prosecution had failed to establish a complete chain of circumstances, that the only eyewitness account was internally contradicted, that the mobile phone recovery was not linked to the deceased, and — most seriously — that the trial court had recorded facts about blood evidence that were directly contradicted by the FSL report on record.

The Conviction Under Appeal

The deceased, Munna Ahirwar, was found dead at the door of one Lakhan Singh. The prosecution case rested entirely on circumstantial evidence: there were no direct eyewitnesses to the killing. The Special Judge convicted Lodhi and sentenced him to undergo imprisonment for life under Section 302 IPC, along with a concurrent life sentence and a fine of Rs. 1,000/- under Section 3(2)(v) of the Prevention of Atrocities Act, with a default simple imprisonment of six months for each fine.

Lodhi challenged the conviction through Criminal Appeal No. 11041 of 2025. His counsel, Shri Madan Singh, argued that the appellant was innocent, that the three circumstances relied upon by the trial court were not connected with each other, and that the prosecution had not established any complete chain. The State, represented by Government Advocate Shri Manas Mani Verma, supported the impugned judgment and sought dismissal of the appeal. With consent of both sides, the appeal was finally heard on the day it was called.

The Eyewitness Account and Its Internal Contradictions

The sole witness to the events of the evening was Chhotelal Ahirwar (PW-7), a relative of the deceased. He testified that on 22 March 2024, the deceased Munna Ahirwar and the appellant were sitting together at the chabutara of his house. Munna Ahirwar gave him Rs. 100/- to fetch liquor from the shop of one Halle. The shop was closed, so he returned the money. Both Munna Ahirwar and Lodhi then walked towards Halle's shop. The witness went to sleep, and the following day found his uncle dead.

The bench found this testimony in direct conflict with the appellant's memorandum. The memorandum stated that Chhotelal Ahirwar had successfully purchased two quarters of liquor from Halle's shop, whereas the witness himself said the shop was closed. This contradiction went to the core of the prosecution's narrative. The bench also noted that Chhotelal Ahirwar's statement under Section 161 of the Code of Criminal Procedure, 1973 was recorded on 4 May 2024 — more than six weeks after the incident of 22/23 March 2024 — and the prosecution offered no explanation for the delay. In cross-examination, the witness also admitted that there was no intimate relationship between the deceased and the appellant.

The Mobile Phone Recovery: An Unproved Link

The second circumstance relied upon by the trial court was the recovery of three currency notes of Rs. 100/- each and a mobile handset valued at Rs. 5,000/- from the appellant's house. The prosecution contended that call records showed communication between the mobile phone of Munna Ahirwar and the appellant, and that the recovered handset established a connection to the deceased.

The bench found the recovery evidence riddled with gaps. The Consumer Application Form (Exhibit P/24) did not mention the IMEI number of the handset; it mentioned only a SIM number, and even that SIM had been seized from the possession of the son of Munna Ahirwar, not from the handset recovered from the appellant. Exhibit P/24 was also described by the bench as neither readable nor legible, and the witness who purportedly proved it — Sudhir Kumar (PW-13) — furnished no details about it. Raghu Keshari (PW-9) made no mention of the IMEI number at all.

The bench applied the Supreme Court's ruling in Mohd. Arif alias Ashfaq v. State (NCT of Delhi), (2011) 13 SCC 621, which had held that each active mobile phone generates records of its unique IMEI number during every call, and that these details must be proved. None of those details were proved in the present case.

Equally, no purchase bill for the mobile handset in the name of Munna Ahirwar or any family member was produced, and no relative of the deceased identified the recovered handset as belonging to him. Without any of these connecting facts, the court held, the recovery of the mobile phone was of no consequence by itself.

The Trial Court's Erroneous Recording of Blood Evidence

The bench's sharpest criticism was reserved for the trial court's treatment of the FSL report. In Paragraph 42 of the impugned judgment, the Special Judge had recorded that human blood was found on Articles E, F and G — the pajama, kameez, and jacket seized from the appellant Lotan Lodhi. The High Court found this to be directly contradicted by the FSL report (Exhibit P/26), which clearly showed that the clothing of Lotan Lodhi did not reveal the presence of human blood. Human blood was found only on the clothing of the deceased Munna Ahirwar.

The bench described this as a perverse finding, contrary to the material on record. It went further and observed that the manner in which the evidence had been appreciated raised <“serious concerns regarding the suitability” of the presiding Special Judge to deal with sensitive matters. Accordingly, the bench directed that the matter be placed before the Acting Chief Justice for appropriate action regarding the trial court judge.

Applying the Sharad Birdhichand Sarda Test

The bench assessed the prosecution's case against the five-point test for circumstantial evidence laid down by the Supreme Court in Sharad Birdhichand Sarda v. State of Maharashtra, (1984) 4 SCC 116, specifically Paragraph 153 of that judgment. That test requires, among other conditions, that the chain of circumstances be complete and point exclusively to the guilt of the accused.

Applying that standard, the bench found that the prosecution had failed on every front. The eyewitness account was contradicted by the appellant's own memorandum. The mobile phone recovery was not linked to the deceased either through identification by family members or through scientific proof that the relevant SIM was being used in the recovered handset. The FSL report actively negated the blood evidence recorded by the trial court. No complete chain of circumstances was established.

Outcome

The Division Bench allowed Criminal Appeal No. 11041 of 2025 and set aside the judgment dated 31 October 2025 passed by the Special Judge, SC/ST (Prevention of Atrocities) Act, District Damoh, in SCATR No. 64/2024. Lotan Lodhi alias Nanna was acquitted of the charges under Section 302 of the Indian Penal Code, 1860 and Section 3(2)(v) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989. The bench directed that he be set at liberty forthwith if his custody was not required in connection with any other case. The trial court record was directed to be sent back immediately. The matter regarding the conduct of the presiding Special Judge was directed to be placed before the Acting Chief Justice.