No one killed 75 CRPF personnel? Chhattisgarh HC acquits 10 in 2010 Tadmetla ambush case: Here is how botched investigation, hostile witnesses caused the case to collapse

The Chhattisgarh High Court recently acquitted 10 accused in the 2010 Tadmetla ambush case, in which Naxalites brutally massacred 76 security personnel and looted their weapons. Passing the order of acquittal, a Division Bench of Chief Justice Ramesh Sinha and Justice Ravindra Agrawal expressed disappointment over the lack of reliable evidence, procedural lapses in the investigation, and failure to establish guilt beyond a reasonable doubt.

The decision was passed on an appeal filed by the state government against the trial court’s acquittal of the accused, as per a judgment passed on January 7, 2013. The Division Bench dismissed the appeal of the state government filed under Section 378 of the CrPC, noting that no direct evidence or eyewitness was available in the case. “In the present case, there is no direct evidence/eyewitness available on record. The case of prosecution is based on the ‘circumstantial evidence’, ” the High Court said in its order dated May 5, 2026.

The High Court expressed dismay over the failure of the prosecution in establishing the identities of the accused, who carried out the barbaric attack. “It is deeply painful to note that despite the loss of 75 personnel of the CRPF, including one member of the State Police, in a brutal attack allegedly carried out by Naxalites, the prosecuting agencies have not been able to establish the identity of the real perpetrators of the crime or bring them to justice for such a barbaric act,” the High Court noted.

“We are equally distressed to observe that a case of such a serious magnitude, involving mass casualties and grave consequences to national security, has ultimately been dealt with in a manner where no legally admissible and reliable evidence could be produced against the accused persons. As a result, the learned trial Court was constrained to acquit them,” the court added.

Lacunae highlighted by the High Court in the prosecution’s case

The High Court highlighted five major lacunae in the case of the prosecution:

Firstly, the High Court said that the prosecution could not furnish any direct evidence or eyewitness testimony linking the accused to the actual commission of the homicidal acts. None of the eyewitnesses identified the accused as the perpetrators of the crime.

Secondly, the confessional statement of the accused recorded under Section 164 Cr.P.C. was not corroborated by any independent evidence.

Thirdly, the explosive material, including pipe bombs, grenades, and rifles, was recovered from the place of the incident and not from the possession of the accused. The Forensic Science Laboratory (FSL) report was not presented before the court, due to which it could not be ascertained that the material recovered from the site was explosive.

Fourthly, the High Court noted that the record did not show a prosecution sanction required under the Arms Act, the Test Identification Parade of the accused was not conducted, and there were discrepancies in witness accounts.

Lastly, the prosecution could not establish the involvement of the accused in planting, handling, or using explosives.

The Advocate General submitted before the High Court that all the witnesses had turned hostile, and they did not identify the accused as the perpetrators of the crime. Besides, the Advocate General failed to provide a satisfactory answer when the court asked the reason for filing the appeal against the trial court judgment, when there was no evidence available to prove the guilt of the accused.

“There is no evidence regarding the prosecution sanction in the case, which is a significant omission. Thus, in the absence of the seizure of prohibited arms and explosive material from the accused, without certification of the seized material as explosive due to the non-production of the FSL report, without evidence of prosecution sanction, and with eyewitnesses not testifying to the involvement of the accused in the crime, it is not established that the accused were found illegally possessing lethal weapons such as guns, in violation of Section 3 of the Arms Act, 1959, or that they used them in the crime,” the High Court observed.

Displeased over the manner of investigation of the case, the High Court asserted that the State must ensure high standards of investigation in future cases involving serious crimes to prevent recurrence of procedural lapses and to uphold
public confidence in the criminal justice system.

Background of the case

The ghastly incident happened on the morning of April 6, 2010, when Satyawan Singh, Deputy Commander, 62nd Battalion CRPF, was on Area Domination Patrol from April 4, 2010, to April 7, 2010, along with the company and police force, going towards the hilly forest of Chintalnar. On their way, the forces were ambushed by Naxalites, who opened heavy fire on them in the forest of Tadmetla village in the Sukma district.

75 CRPF personnel and a police man were killed in the barbaric attack, and their weapons were also looted. Before fleeing from the spot, the Naxalites also planted tiffin bombs. A case was lodged at the Chintagufa police station against the 10 accused. Two of the accused, including 19-year-old Barse Lakhma, who was the youngest accused in the case, died during the trial of the case.