Aslam Alias Imran vs The State of Madhya Pradesh: Supreme Court Case

Aslam Alias Imran vs The State of Madhya Pradesh drew attention due to the Supreme Court’s critical assessment of evidentiary standards in a 30-year-old murder conviction. The Court examined issues like delayed witness statements, procedural lapses and questionable credibility of prosecution witnesses. The decision sparked discussion on the importance of fair investigation and dangers of convicting anyone based on prior enmity or inconsistent evidence. Discover more in-depth analyses of important Supreme Court decisions by exploring Recent Judgements of Supreme Court.

Aslam Alias Imran vs The State of Madhya Pradesh (2025) Introduction

Aslam Alias Imran vs The State of Madhya Pradesh (2025) deals with the conviction of Appellant for the alleged murder of Zahid Khan alias Guddu during a street altercation in Jabalpur. The incident, dating back to 1994, raised complex legal questions about prior enmity, sudden provocation, and the benefit of the doubt in criminal trials. After the conviction was upheld by both the Trial Court and the High Court, the appellant approached the Supreme Court seeking relief.

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The case at hand revolves around the murder of Zahid Khan alias Guddu allegedly committed by the Appellant Aslam alias Imran in broad daylight following a street altercation in Naya Mohalla, Jabalpur. The case involves a conviction under Section 302 of Indian Penal Code, 1860 upheld by both the Trial Court and High Court of Madhya Pradesh, prompting the present appeal before the Supreme Court. The following are the brief facts of Aslam Alias Imran vs The State of Madhya Pradesh -

Incident and Attack

On 22nd August 1994 around 12:30 PM a conflict arose between the Accused-Appellant Aslam alias Imran and deceased Zahid Khan alias Guddu on a public road in Naya Mohalla. The verbal dispute escalated quickly and accused attacked Zahid with a butcher knife (baka). He inflicted multiple injuries on hands and thighs of Zahid and caused a deep neck wound which resulted in heavy bleeding.

Immediate Medical Aid and Death

After the attack, the accused fled the crime scene. Shahid Khan (PW-1) i.e., deceased’s brother along with others took Zahid to Victoria Hospital. Due to the grievous nature of his injuries, doctors referred him to the Medical College. Zahid succumbed to his injuries at 2:10 PM the same day.

Police Intervention and FIR

Following the incident, Sub-Inspector A.K. Bajpai (PW-12) recorded a Dehati Nalishi at 1:30 PM based on initial information. Subsequently, Police registered a First Information Report at Omti Police Station relying on the eyewitness account of Shahid Khan (PW-1).

Inquest and Crime Scene Investigation

Sub-Inspector Vajpayee (PW-11) prepared the Lash Panchnama i.e., inquest report, signed by Shahid Khan and others. Investigators also seized bloodstained soil from the crime scene and sent the body for post-mortem examination.

Arrest and Recovery of Weapon

Police arrested the accused on 25th August 1994. Based on his disclosure statement, the investigating team recovered a bloodstained butcher knife hidden in a container at his residence.

Trial and Conviction by Sessions Court

Upon completion of the investigation, police filed a charge-sheet under Section 302 of Indian Penal Code. The case being triable exclusively by a Sessions Court was committed to the III Additional Sessions Judge, Jabalpur. On 21st November 1995 the Trial Court convicted the Appellant under Section 302 IPC and sentenced him to life imprisonment.

High Court Appeal and Present Appeal

Aggrieved by the decision of the Trial Court, the accused challenged the conviction before the High Court of Madhya Pradesh at Jabalpur. However, on 26th September 2024, the High Court dismissed the appeal and upheld the decision of the Trial Court. The High Court directed the Appellant then out on bail to surrender and serve the remainder of his sentence.

Dissatisfied by the decision of the High Court the accused has now filed the present appeal in the Supreme Court.

The following issues were addressed in Aslam Alias Imran vs The State of Madhya Pradesh
(2025) -

• Whether prior enmity alone is sufficient to establish guilt in a murder case?
• The Court examined whether the existence of prior hostility between the Appellant and deceased could solely serve as a basis for convicting the accused under Section 302 of IPC
• Whether the actions of the Appellant fell under 'murder' as defined in Section 302 IPC or qualified for Exception 4 to Section 300 IPC?
• The defence argued that even if the evidence of the Prosecution was accepted the incident occurred in the heat of the moment during a quarrel where the accused allegedly used the deceased’s own knife. This raised the question in Aslam Alias Imran vs The State of Madhya Pradesh of whether the act constituted culpable homicide not amounting to murder, invoking Exception 4 of Section 300 IPC.
• Whether benefit of the doubt should be extended to the accused due to evidentiary and procedural lapses?
• Given the contradictions, delayed statements and other deficiencies in the investigation, the Supreme Court considered whether these gaps were substantial enough to grant the accused the benefit of the doubt.

Aslam Alias Imran vs The State of Madhya Pradesh (2025) Legal Provisions

Section 302 of Indian Penal Code has an important role in Aslam Alias Imran vs The State of Madhya Pradesh. The following is an analysis of this provision

Section 302 of Indian Penal Code: Punishment for Murder

Section 302 (Now Section 103 of Bharatiya Nyaya Sanhita 2023) deals with punishment for murder. It states that whoever commits murder shall be punished with death, or imprisonment for life, and shall also be liable to fine.

Aslam Alias Imran vs The State of Madhya Pradesh (2025) Judgment and Impact

The Supreme Court in Aslam Alias Imran vs The State of Madhya Pradesh on 27th March, 2024 set aside the conviction of the Appellant in a 30-year-old murder case. The Court cited serious doubts over the credibility of the version of the Prosecution. 

A 2-Judge Bench comprising Justices B.R. Gavai and A.G. Masih observed that prior enmity, capable of establishing motive is a double-edged sword and it can also indicate the possibility of false implication driven by personal vendetta.

The Supreme Court examined the nature and inconsistencies in the evidence of the Prosecution. The Court noted that the benefit of the doubt must be extended to the accused. The deceased known to be a history-sheeter involved in multiple criminal cases including attempt to murder had prior hostility with the Appellant which added to the potential of false accusation.

The Supreme Court in Aslam Alias Imran vs The State of Madhya Pradesh flagged various procedural lapses and inconsistencies

• Lack of bloodstains on the clothes of those who took the deceased to the hospital
• Failure to promptly inform the police despite being in proximity to a constable
• Contradictions among witness testimonies
• Omission of vital details in the medico-legal case (MLC) papers
• A 45-day unexplained delay in recording the statements of key witnesses

On the basis of these findings, the Supreme Court in Aslam Alias Imran vs The State of Madhya Pradesh held that the Prosecution failed to prove the case beyond reasonable doubt. It held that the Appellant was entitled to acquittal. The Supreme Court allowed the appeal and overturned the conviction.

Conclusion

In Aslam Alias Imran vs The State of Madhya Pradesh (2025) the Supreme Court acquitted Aslam alias Imran. The Court held that Prosecution failed to establish guilt beyond reasonable doubt. By highlighting procedural irregularities and the potential misuse of motive, the Court reinforced the principle that suspicion, however strong, cannot replace proof in criminal law.