The same 2 witnesses in 165 FIRs: How a young lawyer exposed Indore Police’s ‘stock witness’ malaise

Every time the call of duty came in August 2024, Salman Qureshi answered. He was there when the police in Indore needed an independent witness to round up men drinking in public. He was there when the police busted men gambling in abandoned homes. He was there when the police arrested men smoking cannabis behind trucks. And he was present once more in the early hours of September 1 when the police stopped a young law intern returning home with a friend after visiting an ailing relative.

This intern was allegedly beaten and stripped by Chandan Nagar police station in Indore, who accused him of riding his motorbike under the influence of alcohol. For the next few months, he spent his time investigating how and why men like Salman Qureshi were miraculously available whenever Chandan Nagar police needed an independent witness.

Last November, 24-year-old Asad Ali Warsi placed his findings before the Supreme Court, which observed that the Indore police’s practice of repeating witnesses, “could be termed anathema to a country governed by the rule of law, like ours.”

An accusation that didn’t add up

Warsi, a resident of Indore’s Green Park Colony, had paid a late-night visit on August 31, 2024, to his ailing maternal aunt. On that ride to Kadhav Ghat in the centre of the city, Warsi was accompanied by his friend Arbaaz Sheikh. It was well past midnight when the boys finally set out for home after scouring several pharmacies in search of medicine. At 1.15 am, Warsi said, a group of constables conducting late-night bandobast duties near the police station asked them to stop.

Warsi alleged that two constables accused him of riding drunk and demanded a bribe of Rs 5,000 to let them go.

“I told them that I am not drunk. I don’t even drink alcohol. I asked them to test me with a breathalyser but they insisted that I come with them to the police station. I refused,” Warsi, who is now a full-time lawyer, told Newslaundry. 

However, the constables were not equipped with a breathalyser. As the standoff continued, Warsi rang the lawyer he was interning with to apprise him of the situation. He also began recording the argument on his phone.

Warsi claimed that the constables ordered him to stop filming. Then, one constable allegedly grabbed Warsi from behind, causing him to drop his phone, while the other slapped his left cheek.

“My phone was shattered,” he said.

The constables then took the boys to the police station and then to a government hospital, where Warsi claimed a doctor drew a blood sample under pressure from the police.

“I told the doctor that the police had beaten me and asked him to note down the injuries. But he only wrote that my left ear hurt,” Warsi recounted.

The doctor found no traces of alcohol in Warsi’s blood sample. Nor did he smell alcohol on Warsi’s breath, the hospital records show.

The boys were taken back to the police station, where the police booked Warsi for the likelihood of disturbing peace and tranquillity. Local residents Amir Rangrez and Salman Qureshi were named as witnesses to the incident. Warsi was allegedly stripped and detained inside the police station and only released the next day.

His priority was retrieving the data from his damaged phone.

“I took the phone to a showroom. I needed to recover the videos, no matter what it took,” he said. Then he prepared to contest the police’s charges.  

The charges against Warsi were heard before the court of the local assistant commissioner of police and executive magistrate. The police argued that Warsi abused the constables who asked him to undergo a blood test and “became ready to fight and assault”. It became necessary to arrest Warsi, the police claimed, because he “indulged in high-volume and unnecessary arguments” and refused to comply with orders.

The court examined the videos that Warsi had recorded and found insufficient evidence for the case to go to trial. On December 17, 2024, the court dismissed the charges against Warsi.

A familiar name crops up

Back at work one evening a few weeks later, Warsi’s senior assigned him research on a client’s defence. Warsi began by reading the FIR.

“It was a case of assault,” he recalled, “and the same witnesses in my case were listed as witnesses again. I couldn’t believe it.”

The discovery got Warsi thinking. Could there be more FIRs in which the same men were listed as witnesses? He logged on the Indore police website for answers. Among the department’s services for citizens is an option to search for FIRs registered in the city. It is part of the union home ministry’s Crime and Criminal Tracking Network and System (CCTNS), which allows citizens to search, read and download FIRs uploaded by the police countrywide.

“I decided to search FIRs registered at Chandan Nagar police station between January and October 2024,” Warsi said.

The results shocked him.

Salman Qureshi and Amir Rangrez seemed to pop up all over Chandan Nagar. On August 11, Qureshi was a witness in nine cases registered that day, followed by eight more the next day. On August 25, exactly a week before Warsi’s run-in with the police, Qureshi was listed as a witness in seven FIRs.

The findings spurred Warsi to dig deeper. Finally, he confined his search to a one-year period – October 10, 2023, to October 10, 2024. He found that of the 176 FIRs in which the police had repeated witnesses, Qureshi and Rangrez figured in 165.  

Having finished his research, Warsi filed a complaint before the magistrate in Indore after his complaints to the state chief minister, home minister, state human rights commission and senior city police officials did not receive a response.  

But it was only after consulting senior advocate Sanjay Hegde that Warsi found a path to bring his findings to the SC’s attention.

“I had a special leave petition ready to be filed. But Sanjay sir and his junior in Indore, advocate Gouransh Vyas, told me to intervene in another matter the SC was hearing,” Warsi said.

The perfect opportunity

That matter was the bail application of Anwar Hussain, a 59-year-old Madhya Pradesh native who worked in a foodgrain godown where rice meant for the state’s public distribution system was seized. Hussain was arrested in November 2024.

Hussain had approached the SC after Madhya Pradesh High Court dismissed his bail plea in March 2025. Opposing his bail plea in October 2025, the police produced a list of seven other offences registered against Hussain, including two at Chandan Nagar police station, citing a criminal record dating back to 2008. The police had compiled the list using the Inter Operable Criminal Justice System (ICJS), which allows courts to access and read scanned copies of FIRs, police station case diaries and chargesheets.

Hussain’s counsel, Dr. Sarvam Ritam Khare, pointed out that four of the eight FIRs cited by the police were unconnected to his client. Of the rest, he had been acquitted in two and court proceedings were underway in the others.

During the next hearing on November 4, 2025, the police apologised to an SC bench of Justices Ahsanuddin Amanullah and Sandeep Mehta for filing a false affidavit. It explained that the error “was purely unintentional and occurred due to reliance on incorrect information extracted from the online ICJS database, which reflected records of another individual having identical particulars.”

That individual was a younger namesake living in Chandan Nagar, booked in two cases of sexual assault and singing obscene songs in public.

The court rejected the police’s “lame excuse” of having mixed up the two men. While granting bail to Hussain, the SC sought an explanation from Chandan Nagar station house officer Indramani Patel and his superior, additional deputy commissioner of police, zone IV, Dishesh Agarwal.

This gave Warsi the perfect opportunity to file an intervention application.

 “I knew that the SC would not ignore what I had to say,” said Warsi, who now practices at the Madhya Pradesh High Court.

The independence and impartiality of the individuals who witness incidents and police procedures often proves the difference between a conviction and acquittal. A witness vouches for the sanctity of police procedures, like searches of suspects or of enclosed spaces. 

The Code of Criminal Procedure and the Bharatiya Nagarik Suraksha Sanhita both dictate that during a search of closed places, the police "shall call two or more independent and respectable inhabitants of the locality." If such individuals cannot be found or do not wish to participate in the proceedings, the police can issue written orders to those individuals to witness the search. 

An unreliable witness opens the police up to allegations of planting evidence on a suspect’s person or her home or tampering with evidence. 

The frequency with which the same witnesses recurred in investigations at Chandan Nagar police station surprised Khare.

“The use of stock witnesses amounts to planting evidence. It means forging or constructing false evidence. It creates a record of what has not happened. We understand that people don’t always want to come forward and co-operate with the police, but in those cases, the police can always note down that no one wished to come forward and list a colleague as a witness,” he said.

Anathema to the rule of law

Before the next hearing, Patel and Agarwal filed affidavits in their defence. In his response, Agarwal wrote that the reoccurrence of witnesses was “being discussed with the senior officials to take appropriate call on the subject ...” He dismissed Warsi’s allegations of misbehaviour and illegal detention as “erroneous and devoid of any factual basis.”

Agarwal’s affidavit also contained Patel’s response. Patel passed the buck on to the 26 investigating officers under his command, who he said, “search for witnesses as per requirement in the field and conduct proceedings in the presence of available witnesses.”

Twenty-five of the 26 investigating officers submitted written explanations to the deputy commissioner of police zone IV. The explanations were brief and nearly identical – that they had only summoned witnesses who were available at the scene of crime. Sub inspector Saurabh Kushwah was among the few to elaborate, admitting that the three crime scene witnesses he used in two offences registered 10 days apart in March 2024 were “residents of the Chandan Nagar area who remain present in the area for work purposes.” One of those witnesses was Amir Rangrez, who is named as a witness in 63 of the 176 cases listed by Warsi.

Patel said that he wasn’t the investigating officer in any of 176 cases listed by Warsi. Investigating officers, he said, work independently and do not inform the SHO about which witness they summon in the field.

However, Patel did shed light on his police station's two most prolific witnesses. Salman Qureshi, Patel said, works in the travel business and lives 600 metres from the spot where the police stopped Warsi. Amir Rangrez, on the other hand, makes tin sheet boxes and lives 900 metres away.

“Their general sitting is mostly at Chandan Nagar square and nearby areas,” Patel said.

Patel also explained why neither witness was visible in the videos of the incident that Warsi recorded on his phone. Warsi shot four videos on his phone - at 1.23 am, 1.24 am, 1.27 am and 1.32 am. According to Patel, the two witnesses arrived at the scene when Warsi was placed under arrest at 1.45 am, after he recorded the videos.

Warsi’s videos, Patel claimed, did not present any proof of “indecency, demand for bribery, and assault committed by the police personnel.”

When the case was next heard on November 25, 2025, Justices Amanullah and K Vinod Chandran observed that Warsi’s intervention had raised “the basic and core issue of conduct of the police” which had “a direct bearing on the confidence of the public.”

Then, after Agarwal said that he would forward Warsi’s intervention application to his superior officers, the SC made Indore police commissioner Santosh Kumar Singh a respondent and directed him to file his response in an affidavit.

The court took up Singh’s affidavit in the next hearing, on January 13, 2026. Singh wrote that only weeks previously, he had issued a citywide circular to his subordinates stressing the need for “independent, respected and impartial witnesses.”

“Every witness presented in criminal cases must hold credibility, be impartial, selfless, and neutral. Therefore, in criminal cases during the process of search, seizure, raid, arrest, etc., a respected, locally available witness should be given priority,” stated Singh’s circular.

In the event that a local independent witness was unavailable or did not cooperate, Singh directed his subordinates to call another person as a witness after noting the details of the earlier witness in the police station’s case diary. 

“Even if he or she has previously appeared as a prosecution witness in another case, it is essential that the witness be independent, impartial, credible, and neutral and that the police proceedings be transparent, so that the witness's credibility can be presented strongly in front of the Hon’ble Court,” Singh wrote.

Like Patel and Agarwal, Singh denied that the police had assaulted Warsi or stripped him of his clothing.  

At the end of the hearing, Justices Amanullah and R Mahadevan ordered that Patel be transferred from Chandan Nagar police station to the city police headquarters “without assigning any duty of investigating/supervising any investigation/posting in a police station” until further orders. The court observed that Patel’s practice of using stock witnesses went “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.”

The court also warned Singh that he would be personally held responsible and answerable if Patel interfered in any police station in any manner. 

The SC also took note of another complaint being heard against Patel at the MP High Court late last year. In November 2025, Patel detained and handcuffed an individual named Raja Dubey inside the police station for over 24 hours. Patel explained that even as the police were looking for Dubey’s father in connection with an ongoing investigation, they summoned his son and handcuffed him to prevent him from fleeing. Patel admitted that he had not obtained an order from the court to handcuff Dubey. 

Noting that Patel’s illegal act was in “gross violation of the fundamental right to life of a citizen”, the HC had directed Singh to file a response on what departmental and criminal action he proposed to initiate against the Chandan Nagar SHO. 

Singh did not respond to a phone call and text messages seeking his comment. 

In court on Tuesday, Additional Solicitor General K M Nataraj proposed that the Madhya Pradesh government would suggest guidelines to check the police’s practice of using stock witnesses when the matter is next heard on March 10.  

However, Warsi’s lawyer, Ashish Pandey, would like to see Patel prosecuted. “He has misused the power given to him by the Constitution. An FIR should be filed against him,” Pandey said.

The SC’s directions are just what Warsi expected. When he looks back at that night from a year and a half ago, Warsi credits his legal education and presence of mind for the courage to stand up to the police.

“I knew my rights, which is why I started recording. If everyone starts making a video of their arrests, false arrests won’t happen. This is a lesson to the police. They should fear doing something like this again,” he said.

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