In a detailed judgment delivered on February 20, 2026, the Supreme Court dismissed the criminal appeal filed by Neelu alias Nilesh Koshti, affirming his conviction for the murder of Archana alias Pinki in Indore.
The Bench of Justice Prashant Kumar Mishra and Justice Vipul M. Pancholi held that the chain of circumstances was complete and pointed only to the appellant’s guilt. The Court upheld the life sentence imposed under Sections 302 (murder) and 201 (destruction of evidence) of the Indian Penal Code.
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Background of the Case
The case dates back to July 2009. Archana alias Pinki went missing on July 25. Three days later, her mother lodged a missing report at Pardeshipura Police Station in Indore .
During the investigation, police found that ransom calls demanding ₹5 lakh were made from the deceased’s mobile phone to her husband. The phone later surfaced in the hands of third parties, who stated that they had purchased it from the appellant.
On August 10, 2009, the appellant allegedly gave a statement to police that led to the recovery of Archana’s body from a well near Indore bypass road. The body was found stuffed in a sack.
The Trial Court convicted him. The Madhya Pradesh High Court later upheld the conviction. The matter then reached the Supreme Court.
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Arguments Before the Court
The defence argued that there was an unexplained delay of three days in filing the missing report. It also claimed that there was no solid proof of ransom calls and that no DNA test was conducted to confirm the identity of the body recovered.
Further, it was argued that call detail records were not properly produced and that the prosecution case rested entirely on circumstantial evidence without any eyewitness.
On the other hand, the State maintained that each circumstance was clearly established and collectively formed a complete chain.
Court’s Observation on Circumstantial Evidence
The Bench made it clear that the case rested entirely on circumstantial evidence. Referring to the landmark ruling in Sharad Birdhichand Sarda v. State of Maharashtra, the Court reiterated that all links in the chain must be firmly established.
“The circumstances, when viewed cumulatively, form a complete chain. No other reasonable conclusion is possible except that the appellant committed the murder,” the Bench observed .
The Court rejected the argument regarding delay in lodging the missing report. It noted that families often conduct their own search before approaching police and a three-day delay was not unusual.
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Recovery of the Body and Section 27 Evidence
A crucial part of the case was the recovery of the body based on the appellant’s statement while in police custody.
The Court explained Section 27 of the Evidence Act in simple terms - when an accused gives information in custody that leads to the discovery of a fact, that specific part of the statement can be used as evidence.
Here, the body was recovered from a well at the exact location disclosed by the appellant. The Court said this showed his “exclusive knowledge” of where the body had been hidden .
The Bench described this as a “formidable link” in the prosecution’s case.
Identification of the Body
The defence questioned the absence of a DNA test. However, the Court noted that the body, though partially decomposed, was identified by close relatives and a local auto driver who knew the deceased.
The medical evidence showed ligature marks on the neck, a fracture in the thyroid cartilage, and signs of strangulation. The Court concluded that the death was clearly homicidal .
Other Key Circumstances
The deceased’s mobile phone was traced back to the appellant, who had sold it after her disappearance.
Her scooty was also recovered from a railway station parking stand at his instance.
On motive, the prosecution alleged that the appellant had conspired to demand ransom and later killed her. The Court clarified that while motive strengthens a case, it is not always essential if other evidence is strong.
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Decision
After examining every circumstance, the Supreme Court found no break in the chain of evidence.
“We find ourselves in complete agreement with the concurrent findings of both the Courts below,” the Bench stated while dismissing the appeal .
The conviction and life sentence were upheld. However, noting that the appellant has spent over 15 years in prison, the Court granted him liberty to apply for remission, which the State may consider under its policy.
Case Title: Neelu @ Nilesh Koshti v. State of Madhya Pradesh
Case No.: Criminal Appeal No. 5357 of 2025
Decision Date: February 20, 2026
