The Madhya Pradesh High Court has set aside an order of a Special Judge that had refused to accept a closure report submitted by a Supreme Court-appointed Special Investigation Team (SIT) in connection with the death of Nilesh Adivasi. The Court held that the victim's widow, Reva Adivasi, was entitled to a meaningful opportunity of hearing before any decision was taken on the closure report.
Delivering the judgment, Justice Himanshu Joshi emphasized that procedural fairness is an essential part of criminal justice and cannot be ignored even when the eventual outcome appears to favour the complainant.
Background of the Case
The controversy traces back to an FIR registered in July 2025 at Malthone Police Station in Sagar district based on allegations made by Nilesh Adivasi. Soon after, Nilesh submitted an affidavit and later gave statements before authorities retracting those allegations.
On July 25, 2025, Nilesh died by suicide. Following his death, his widow Reva Adivasi alleged that her husband had been subjected to pressure and intimidation after withdrawing his earlier allegations. She sought a proper investigation into the circumstances surrounding his death.
Based on her complaints, another FIR was registered in September 2025 against Govind Singh Rajpoot and others for offences including abetment of suicide and provisions under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act.
The Supreme Court later directed the constitution of an SIT to investigate the matter and related FIRs. After completing its investigation, the SIT submitted a closure report before the Special Judge in Sagar.
Challenge Before the High Court
Two separate petitions were filed before the High Court.
Govind Singh Rajpoot challenged the Special Judge's decision rejecting the SIT closure report, arguing that the order lacked proper reasoning and ignored important material collected during the investigation.
Meanwhile, Reva Adivasi challenged the same order on a different ground. She contended that she had not been supplied with the closure report and supporting documents and was not given an effective opportunity to oppose the SIT's findings before the court considered the report.
Court's Observations
The High Court chose to focus on a narrow but important legal question—whether a court can decide a closure report without first giving the complainant or victim an effective opportunity of hearing.
Justice Joshi noted that Reva Adivasi was not merely a formal informant but the widow of the deceased and the person whose complaint led to the registration of the case.
Referring to the Supreme Court's ruling in Bhagwant Singh v. Commissioner of Police, the Court reiterated that an informant must be notified and heard before a court takes a final decision on a police closure report.
The Court observed:
“Judicial orders must not only be fair in their outcome but must also be fair in the process by which they are arrived at.”
The bench further stated that the right to be heard cannot be treated as unnecessary merely because the final order appears to benefit the complainant.
According to the Court,
“The opportunity of hearing must precede the formation of judicial opinion.”
High Court's Decision
Without expressing any view on the merits of the allegations, the correctness of the SIT investigation, or the validity of the closure report, the High Court held that the Special Judge's order dated March 18, 2026 could not be sustained because Reva Adivasi had not been given an effective opportunity of hearing before the closure report was considered.
The Court consequently set aside the Special Judge's order and remanded the matter for fresh consideration. It directed the Special Judge to ensure that Reva Adivasi is served notice, allowed to inspect and obtain the materials accompanying the closure report, and given a meaningful opportunity to present her objections. Thereafter, the court must reconsider the closure report independently and pass a fresh reasoned order in accordance with law.
The High Court clarified that it had not expressed any opinion on the merits of the case and left all factual and legal issues open for consideration by the Special Judge.
Case Details
Case Title: Govind Singh Rajpoot v. State of Madhya Pradesh & Others; Reva Adivasi v. State of Madhya Pradesh & Others
Case Number: Writ Petition No. 10310 of 2026 and Writ Petition No. 10396 of 2026
Judge: Justice Himanshu Joshi
Decision Date: June 16, 2026
