Court Affirms Conviction in Four-Murder Case
The Supreme Court upholds life sentence in Satna murder case, reaffirming the conviction of Upendra Khare in the 2002 quadruple murder case from Satna, Madhya Pradesh. The Court held that the recovery of incriminating articles at his instance, supported by medical and forensic evidence, formed a crucial link in the chain of circumstances proving his guilt. Accordingly, the Supreme Court upholds life sentence in Satna murder case after finding no error in the concurrent findings of the Trial Court and the High Court.
A Bench of Justice Pankaj Mithal and Justice Prasanna B. Varale delivered the judgment on May 25, 2026, in Upendra Khare v. State of Madhya Pradesh, Criminal Appeal No. 1937 of 2013. Justice Prasanna B. Varale authored the judgment. Ultimately, the Court dismissed the appeal against the Madhya Pradesh High Court judgment dated June 21, 2012.
Background of the Case
The case arose from an incident reported on July 20, 2002. Anupam Shukla informed Police Station City Kotwali, Satna, that his cousin Rajesh Shukla had been unreachable since July 18.
When family members entered Rajesh Shukla’s house, they found the bodies of Rajesh Shukla, his wife Madhu Shukla, their son Prabhanshu Shukla, and Rajesh’s sister Vinita Shukla. All four had suffered multiple injuries.
Police registered FIR No. 515 of 2002 under Section 302 IPC. They also recovered blood-stained clothes, bedsheets, and empty Calmpose injection phials from the scene.
Post-mortem reports showed that the victims died from excessive blood loss caused by sharp-edged weapons. Subsequently, investigators noticed missing jewellery and added offences under Sections 382 and 404 IPC.
During the investigation, police found that co-accused Devendra Singh allegedly harassed Vinita Shukla. According to the prosecution, Devendra Singh, Upendra Khare, and others entered the house, administered Calmpose injections, and murdered the victims.
Later, police recovered a country-made pistol, live cartridges, and stolen jewellery from different accused persons. They also recovered empty Calmpose injection phials, clothes, a cotton rope, and used syringes at Upendra Khare’s instance.
After completing the investigation, police filed chargesheets against several accused. They charged Upendra Khare under Sections 302, 382, and 404 read with Section 149 IPC.
Trial Court and High Court Findings
The First Additional Sessions Judge, Satna, convicted Upendra Khare under Section 302 read with Section 149 IPC on four counts. The court sentenced him to life imprisonment and imposed a fine of ₹1,000.
However, the Trial Court acquitted him of offences under Sections 382 and 404 IPC by extending the benefit of doubt.
Later, the Madhya Pradesh High Court upheld the conviction on June 21, 2012. It also clarified that all four life sentences would run concurrently.
Arguments Before the Supreme Court
Advocate Amit Singh, appearing for the appellant, argued that the prosecution relied entirely on circumstantial evidence. Therefore, he submitted that the chain of circumstances remained incomplete.
He further contended that the prosecution attributed no motive to Upendra Khare. Instead, it alleged motive only against co-accused Devendra Singh.
Additionally, the appellant argued that police recovered neither stolen property nor the murder weapon from him. He questioned the reliability of the recoveries because independent seizure witnesses turned hostile. He also argued that police made the recoveries nearly two months after the incident and allegedly coerced him during custody.
To support his case, the defence relied on Prabhu v. State of U.P., Boby v. State of Kerala, and Ashish Batham v. State of Madhya Pradesh.
The appellant further argued that forensic reports did not establish that the blood stains on the recovered clothes were human blood. Moreover, he claimed that the recovered rope had no connection with the murders.
He also challenged his conviction under Section 302 read with Section 149 IPC, arguing that fewer than five persons ultimately stood convicted. Alternatively, he sought reduction of his sentence to the period already undergone.
On the other hand, Deputy Advocate General Bhupendra Pratap Singh opposed the appeal. He argued that the prosecution had established a complete chain of circumstantial evidence. In support of his submissions, he relied on Goverdhan v. State of Chhattisgarh to contend that hostile panch witnesses do not invalidate recovery evidence.
Supreme Court’s Analysis
The Supreme Court noted that the prosecution case rested on circumstantial evidence. In particular, it identified the recovery of Calmpose injection phials, clothes, and a rope at the appellant’s instance as the principal incriminating circumstance.
The Bench examined the testimony of PW-17 Dr. B.L. Gupta. According to the doctor, the victims suffered multiple penetrating and incised injuries that caused fatal blood loss. Moreover, chemical analysis of the viscera confirmed the presence of Diazepam.
The Court rejected the appellant’s challenge to the recovery evidence. It held that the investigating officer can validly prove recoveries even if seizure witnesses turn hostile.
For this reason, the Bench relied on Rameshbhai Mohanbhai Koli v. State of Gujarat and Mallikarjun v. State of Karnataka to reaffirm the settled legal principle.
Although the Court observed that investigators did not conduct the investigation with the expected level of care, it held that investigative lapses alone cannot erase otherwise reliable evidence.
Furthermore, the Bench found that the recovered injection phials, read with the medical and forensic evidence, formed an important incriminating circumstance against the appellant.
Appeal Dismissed
After examining the record, the Supreme Court found no reason to interfere with the concurrent findings recorded by the Trial Court and the High Court.
Accordingly, it dismissed the appeal and affirmed Upendra Khare’s conviction and life sentence under Section 302 IPC.
