At the centre of the Supreme Court’s recent directive while raising questions on the practice of using stock witnesses by the Indore police stand the city’s Chandan Nagar Police Station, and its Station House Officer, Inspector Indramani Patel.
On January 13, a Supreme Court Bench of Justices Ahsanuddin Amanullah and R Mahadevan directed that Patel be sent to police lines and prohibited from any investigating or supervising role until further orders. The Court was hearing an application that challenged the dismissal of a bail plea filed by a person arrested by Patel’s team.
The Bench determined that Patel “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”.
Patel was accused of using recurring witnesses across 176 criminal cases, fabricating criminal records presented to courts, and illegally detaining and handcuffing a citizen without judicial authorization. Of these 176 FIRs, filed between November 10, 2023, and November 13, 2024, stock witnesses were allegedly used in 78 excise cases, 62 narcotics cases, and 25 Arms Act cases.
In his reply to the Court, Patel said of the 176 cases that “I am not the investigating officer in even one”. He said 26 investigators in all had conducted spot seizures and investigation proceedings in the cases, and in the seizure proceedings, 35 independent witnesses had supported the on-the-spot proceedings.
The case that blew the lid
Booked in November 2024 over a complaint by locals, Anwar Hussain, who remains in jail, filed a special leave application before the Supreme Court after the High Court dismissed his bail plea.
The initial case involved an accusation against Hussain of “earning profit by selling the rice allotted for the Public Distribution System… in the open market”.
Story continues below this ad
Opposing his SLP before the Supreme Court, police claimed a number of charges against Hussain: of theft, under the Arms Act dating back to 2008 and 2009, and of rape and criminal intimidation filed in 2023 at the Chandan Nagar Police Station.
Later, however, the Madhya Pradesh government rendered an unconditional apology in the case, for “inadvertently mentioning incorrect antecedents” of Hussain. Its corrected criminal records showed Hussain as an accused only in charges of obscene acts and songs, voluntarily causing hurt and criminal intimidation, and under the essential commodities Act. Court records showed that of the four cases, one had been concluded after both parties reached a compromise.
In his defence over the application of “incorrect antecedents” for Hussain, Patel claimed mistaken identity, saying data pulled from police records had bunched together two accused with the same name and father’s name.
Meanwhile, after he came to know of Hussain’s case, Asad Ali, a Madhya Pradesh High Court lawyer, filed an intervention application in the Supreme Court on November 20, 2025.
Story continues below this ad
In August 2024, Ali had been booked by the Chandan Nagar police during routine checking, for allegedly assaulting policemen on duty and refusing to cooperate with a medical examination. In December 2024, Ali was acquitted for lack of evidence, and filed a complaint against the police officials before a Judicial Magistrate First Class in Indore.
In his application in the Supreme Court filed in November, Ali accused SHO Patel of using stock witnesses to charge him after he refused to pay a bribe to police, and said “police officials have systematically used their statutory powers with mala fide intent” to oppress “numerous other innocent citizens”.
Ali’s lawyers produced FIR records registered in a span of one year containing the names of the same witnesses in 176 police cases, saying it was clear evidence of “the pattern of abuse”.
The Supreme Court also took note of a habeas corpus petition by one Raja Dubey alleging that his brother-in-law, who had committed no office, had been illegally detained and handcuffed by Inspector Patel in November 2025.
Story continues below this ad
Summoned before it by the Indore Bench of the High Court in the case in December, Patel had not disputed that Dubey was “detained at the police station and also handcuffed”, but justified it on the grounds of “the seriousness of the alleged offense”. Patel admitted that no order was obtained from court for handcuffing.
The High Court had then observed: “… we find that the action of Indramani Patel… is in gross violation of the fundamental right of life of a citizen… the Commissioner of Police, Indore, is directed to submit a response (as to) what departmental action and criminal action is proposed against the said officer”.
The Supreme Court relied on the observations of the High Court when it directed Patel’s transfer.
By then, in light of questions raised by the apex court during hearings in Ali’s application, police had initiated action against Patel. Indore DCP Zone 4 Anand Kaladgi issued a show cause notice to him on November 27, 2025. In a December 7 report, Kaladgi stated that it was found that in “176 cases mentioned in the intervention petition, the selection of witnesses was based on the availability of the person at the place of the incident”.
Story continues below this ad
Indore Commissioner of Police Santosh Kumar Singh also noted the use of stock witnesses, “wherein 37 such witnesses have been used, and multiple times, by the… 26 investigation officers” and said that until the report from investigating officers is received on it, “alternative measures shall be deliberated in discussion with all the stakeholders” for fairness.
