A division bench of Justice Vivek Agrawal and Justice Ramkumar Chaube, sitting at the High Court’s principal bench in Jabalpur, dismissed the appeal filed by the convict’s family challenging the verdict of the Special POCSO Court. The bench observed that the crime was marked by extreme cruelty and inhuman conduct that shook the collective conscience of society.

The court noted that the nature of violence inflicted on the child and the circumstances surrounding her death reflected exceptional depravity. In its judgment, the bench said the suffering endured by the victim in her final moments was beyond description and that even the thought of such an act was deeply disturbing. These factors, it held, justified the imposition of capital punishment.

The High Court also took serious note of the conduct of the accused after the crime. It recorded that the child’s body was concealed in a water tank at the accused’s residence for several days, describing this as further evidence of mental cruelty and a calculated attempt to destroy evidence.

The prosecution was represented by Special Public Prosecutor Divya Shukla. The court agreed with the trial court’s findings that the prosecution had established a complete and unbroken chain of evidence, leaving no doubt about the guilt of the accused. The judges said the evidence on record clearly linked the accused to the crime, warranting confirmation of the sentence.

The Special POCSO Court in Bhopal had delivered its verdict on March 18, 2025, concluding the trial within six months. The court had awarded the death penalty for three offences—kidnapping, rape and murder—making it the first case in Madhya Pradesh to impose a “triple death sentence” under the Bharatiya Nyaya Sanhita (BNS). The trial court had then remarked that if a punishment more severe than death existed, it would have been appropriate in this case.

Atul Nihale, aged 30, worked as a labourer. In addition to the death sentence, he was also awarded double life imprisonment under other provisions of law. His mother, Basanti Nihale, and sister, Chanchal, were sentenced to two years’ imprisonment each for concealing evidence.

The case dates back to September 24, 2024, when the child went missing while playing near her uncle’s flat. Her body was recovered two days later from the accused’s house. With the High Court’s ruling, the confirmation of the death sentence underscores the judiciary’s firm stance against crimes involving extreme violence against children.