missing minor girls in MP

Disclaimer: This has been reported after the availability of the order of the Court and not on media reports so as to give an accurate report to our readers.

Madhya Pradesh High Court: In a public interest litigation filed by a flesh trade survivor seeking protection and rescue of missing minor girls in MP, the Division Bench of G. S. Ahluwalia and Anil Verma, JJ., directed the Police Authorities to file replies mentioning the details of missing girls in Gwalior and Shivpuri.  

Background

The instant PIL was filed by a woman, aged 36 years, who claimed to be a survivor of the flesh trade. She stated that she was forced into the flesh trade at the age of 9 years, and after suffering for many years, she survived. Thus, she did not want other girls to undergo the same agony and pain.

She also levelled certain allegations against respondents 8 to 14, who were allegedly involved in such illegal activities.

Since the controversy involves a burning issue, the Court had previously directed the Government Advocate to call the Inspector General of Police, Gwalior (“IGP”), and if possible, Superintendent of Police, Shivpuri (“SP”), to give the Court a bird’s eye view of the efforts being made by the Police.

Analysis

The Court stated that the issue involved in the present case gave a very alarming and precarious condition of the minor girls who went missing.

“We do not know whether those girls have voluntarily gone from their houses or whether they were thrown into the flesh trade.”

Regarding the SP’s submission that at present 30 girls were missing from Shivpuri and in 2025, 228 minor girls went missing out of which 210 girls were recovered, the Court stated that the SP was not aware whether all those girls were actually recovered by the Police, came back voluntarily to their houses, or gone to the police station. The SP sought time to collect the said figure, as he would need to review each case diary.

The Court noted that, as per the SP, out of 30 unrecovered minor girls, one girl went missing in 2014, 2015, 2021, and 2022 each, two in 2019, three in 2023 and 2024 each, and 18 in 2025. 10. Noting this, the Court remarked that, “It is really shocking that some of the girls are missing for more than 10 years, but still, police are not in a position to find out their whereabouts.” Furthermore, the Court added that it was unknown whether the Police Headquarters had issued any specific direction to the police stations concerned regarding the missing girls for the last 10 years.

Under these circumstances, the Court granted a week to the State to file a specific reply on behalf of the IGP and SP separately, providing the following information:

  1. Gwalior Zone

    1. How many minor girls went missing from 2014 to 2025?

    2. How many minor girls were recovered?

    3. How many minor girls had voluntarily come back to their houses or had gone to the police?

    4. In how many cases had the police actually traced out the girls and apprehended the accused?

    5. If the IGP finds that some drastic improvements are required for improving the situation of recovery of missing minor girls, then he shall also point out the same.

  2. Shivpuri

    1. How many minor girls went missing from 2014 to 2025?

    2. How many minor girls were recovered?

    3. How many minor girls had voluntarily come back to their houses or had gone to the police?

    4. In how many cases had the police actually traced out the girls and apprehended the accused?

The Court also issued notice to the National Commission for Women to rise to the occasion and actively assist the Court in arriving at the right conclusion, which would effectively protect the dignity and life of the minor girls.

Accordingly, the matter was listed for 19-01-2026.

[L v. State of Madhya Pradesh, 2026 SCC OnLine MP 176, decided on 07-01-2026]


Advocates who appeared in this case:

For the petitioner: Rishikesh Bohare

For the respondent: Deputy Solicitor General Praveen Kumar Newaskar, Government Advocate S.S. Kushwah, Advocate R.K. Shrivastava

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