The Supreme Court ordered removal of an Indore SHO from investigative and supervisory duties after prima facie noting repeated use of identical stock witnesses in multiple cases. The officer was sent to police lines, barred from investigation, pending orders.
NEW DELHI: The Supreme Court has recently mandated the removal of a Station House Officer (SHO) in Indore from all investigative and supervisory tasks. This decision followed findings that he had permitted the repeated use of the same “stock witnesses” across various cases.
A Bench consisting of Justice Ahsanuddin Amanullah and Justice R. Mahadevan instructed that the officer, Indramani Patel, be reassigned to the police lines until further notice, prohibiting him from engaging in any investigation related activities.
Furthermore, the Court emphasized that the Commissioner of Police in Indore would be held personally accountable should Patel interfere in any police actions.
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Highlighting the serious implications of Patel’s actions, the Court indicated that an interim order was necessary given the evidence against him. It required the State to submit an affidavit confirming that the SHO had indeed been moved to the police lines.
In explaining the rationale behind this significant decision, the Court asserted that the continual use of the same witnesses in different cases undermines the fairness of criminal investigations and contradicts the foundational principles of the rule of law.
The Court remarked,
“Respondent No.4 (the SHO) has, prima facie, resorted to/allowed repeated use of the same witnesses in support of the police versions of alleged crimes i.e., ‘stock witnesses’, a practice which goes to the very root of fairness and impartiality of investigation and could be termed anathema to a country governed by the rule of law, like ours,”
This ruling was issued on January 13 in response to a bail petition filed by Anwar Hussain. The State of Madhya Pradesh had previously opposed Hussain’s plea, submitting that eight criminal cases were ongoing against him. Hussain’s legal team contended that he was not named in four cases, had been acquitted in two, and that only two cases were truly pending.
Faced with this reality, the State acknowledged inaccuracies in its affidavit, attributing the errors to the similarities between Hussain’s and his father’s names in a computer generated report.
The Court dismissed this explanation and granted bail to Hussain, underscoring the threat to his liberty. However, proceedings did not end there; the Court issued notices to two senior police officials a Deputy Commissioner of Police (DCP) and the Station House Officer asking them to explain why they should not face action for presenting misleading information.
By November 25, an intervention application presented further evidence regarding the police’s conduct. The Court remarked that these matters touched upon “the basic and core issue” of police behavior and public trust. It then included the SHO, the Additional DCP, and the Commissioner of Police, Indore, as parties in the case, directing them to submit personal affidavits.
While the Supreme Court case was ongoing, the same SHO faced scrutiny from the Madhya Pradesh High Court in December 2025. In a habeas corpus matter, the High Court noted that an individual had been unlawfully detained and handcuffed without a court order.
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The SHO admitted that he acted without legal authority, prompting the High Court to label this a severe violation of Article 21 and request information on the proposed actions against the officer from the Commissioner of Police.
Considering these developments, the Supreme Court stated,
“As such, we are fortified in our view that immediate directions, as passed hereinabove, were required. Of course, we clarify that the present Order is interim in nature, and our findings, in praesenti, are tentative.”
The next hearing is scheduled for February 3, during which the roles of the Commissioner of Police and the Additional DCP will be scrutinized.
Hussain was represented by advocates Sarvam Ritam Khare, Shweta Chaurasia, Kushagra Sharma, Anuj Agarwal, and Akarsh Khare. The State and the police officials were represented by Additional Solicitor General KM Nataraj, along with Senior Advocates Siddharth Aggarwal, Siddharth Dave, Gagan Gupta, and Sanjay Hegde, as well as various other legal representatives.
Case Title: Anwar Hussain vs. The State of Madhya Pradesh
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