MP High Court Questions Police Inaction, Orders CBI Investigation Into Excise Officer Bribery Allegations

The Madhya Pradesh High Court has handed over to the CBI the investigation into the alleged suicide of a liquor contractor from Dewas, observing that the police appeared to be making efforts to “brush under the carpet” serious allegations of corruption levelled against a senior Excise Department officer. The Court said the material placed before it prima facie disclosed the commission of a cognisable offence and raised serious doubts about the fairness of the local police investigation.

Justice Subodh Abhyankar passed the order while hearing a petition filed by Santosh, mother of deceased liquor contractor Dinesh Makwana, who allegedly died by suicide after consuming Celphos on November 8, 2025. The petitioner alleged that Mandakini Dixit, then Assistant Commissioner in the Excise Department at Dewas, had been demanding illegal payments from her son and harassing him over liquor business operations.

Appearing for the petitioner, Advocate Ashish Gupta argued that despite a suicide video recorded by the deceased clearly naming the officer and detailing the alleged bribery demands, the Kanadia police station failed to even register an FIR. Gupta also referred to another video allegedly showing the officer attempting to settle the matter with the family and offering to bear the educational expenses of the deceased’s children.

According to the Court record, Makwana claimed in his suicide video that he operated multiple liquor shops in Dewas district and was being forced to pay Rs.1.5 lakh per month per shop to the officer. He also alleged that she demanded commission on every liquor bottle sold and threatened to stop supply from warehouses whenever payments were delayed.

Senior Advocate S.K. Vyas, appearing for Dixit along with Advocates Yash Agrawal and Shashank Shekhar Rai, opposed the plea for a CBI probe. The defence argued that the video clip had been examined by a private forensic expert who opined that it was tampered with, selectively edited and non-continuous. It was further argued that Makwana was already under financial stress because of departmental dues amounting to Rs.34 lakh and had received a show-cause notice warning of licence cancellation and forfeiture of bank guarantees.

The State government, represented by Government Advocate Hemant Sharma, also opposed the transfer of investigation to the CBI. The State relied upon a Cyber Forensic Lab report stating that the video clip was not created from the same phone allegedly belonging to the deceased and appeared to have been transferred from another device.

The High Court, however, refused to discard the suicide video merely because it was allegedly recorded more than a month before Makwana’s death. “When a person is pushed to such an extent to commit suicide, merely because he does not commit suicide immediately after recording of the suicide note, would not make his case less believable,” the Court observed.

The Court further noted that despite the suicide video being submitted to the police in November 2025, no FIR had been registered for months. Calling the police conduct deeply concerning, the Court remarked that “desperation” to delay registration of the FIR required “desperate measure” from the judiciary.

Holding that the credibility of the investigation itself had come under question, the Court directed Police Station Kanadia in Indore district to immediately transfer the case to the CBI for registration of FIR and further investigation. The Court clarified that serious allegations of corruption against a high-ranking government officer could not be ignored lightly and required an independent and fair probe.

While directing the transfer, the High Court relied upon the ruling in Legislative Council U.P. Lucknow v. Sushil Kumar, which held that CBI investigations should be ordered sparingly but may become necessary where the credibility of the probe is doubtful. The Court distinguished the judgment cited by the respondent on abetment of suicide under Section 306 IPC, observing that the dispute was at the stage where registration of an FIR had been resisted despite “serious allegations of corruption” against a senior public official.

Case Title: Santosh v. The State of Madhya Pradesh and Others

Date of Order: April 18, 2026

Bench: Justice Subodh Abhyankar