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Freedom251 › Blog › FIR 219/2021

Five Years On, Lakhimpur Kheri Trials Show Contrasting Progress Amid Fresh Supreme Court Scrutiny

By Freedom251 Team · · 3 min read

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Five years after the October 2021 violence in Lakhimpur Kheri, the trial in FIR 220/2021 was reported close to final arguments, while FIR 219/2021 remained under renewed Supreme Court scrutiny over witness handling and the public prosecutor. The latest figures come from Hindustan Times on October 3, 2026; the most recent Supreme Court order in the sources cited here is dated December 11, 2025.

What the two Lakhimpur Kheri cases concern

On October 3, 2021, a vehicle convoy incident in Tikunia, Lakhimpur Kheri, killed four protesting farmers and a journalist. Violence that followed killed three more people. The resulting proceedings are separate cases involving different accused groups and allegations.

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  • FIR 219/2021 concerns the convoy deaths and was registered against Ashish Mishra and others.
  • FIR 220/2021 followed a complaint by BJP leader Sumit Jaiswal and concerns allegations against farmers after the violence.

Progress in one case does not decide the allegations in the other. Neither trial had concluded in the updates reported here.

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How far each trial had progressed

Case Latest progress reported Earlier official snapshot
FIR 219/2021 Hindustan Times reported on October 3, 2026 that the original list of 441 witnesses had been reduced to 103. The report did not give a new count of how many of those 103 had yet to testify or say that final arguments were imminent. In its December 11, 2025 order, the Supreme Court recorded the State’s status report: 36 witnesses examined, 10 exempted and 85 awaiting examination.
FIR 220/2021 Hindustan Times reported on October 3, 2026 that all 87 witnesses had deposed and final arguments were to begin. In its December 11, 2025 order, the Supreme Court recorded the State’s position that 25 of 35 proposed witnesses had deposed and 10 were awaiting examination.

The counts should be read as dated snapshots, not combined into a single running total. In particular, the Supreme Court’s December 2025 figures for FIR 220/2021 refer to 35 proposed witnesses, while the October 2026 report gives a figure of 87 witnesses who had deposed; the sources cited here do not explain the difference in the figures or their counting basis.

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Why FIR 219/2021 has drawn fresh scrutiny

Hindustan Times reported on October 3, 2026 that the Supreme Court directed Uttar Pradesh to replace public prosecutor PB Mishra with a senior prosecutor experienced in trials, within two weeks. The report said the direction followed concerns that witnesses were being given up. It also said the Court sought a sealed-cover report from the Allahabad High Court Chief Justice on complaints about the presiding judge.

The account reproduced the bench’s criticism: “What is unusual is that on a given date when the witnesses are called, why should the public prosecutor give up those witnesses. They are eyewitnesses. This may not be a very fair prosecution if the PP (public prosecutor) gives up on witnesses.” Hindustan Times attributed a separate remark—“Sir, I do not want to examine all these witnesses”—to the prosecutor, recounting victims’ counsel Prashant Bhushan’s account. That is an attributed courtroom account, not a transcript or a finding by the Court in the sources cited here.

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The Indian Express reported on September 23, 2026 that the Supreme Court directed the Allahabad High Court Chief Justice to examine victim-family concerns and report on action taken, and directed the State to identify a senior, experienced prosecutor. Claims about witness intimidation, medical exemptions, intimidation of relatives or prosecutorial conduct were submissions reported from advocates; the cited accounts do not establish those disputed claims as proven misconduct or fact.

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What the Supreme Court’s 2025 orders recorded

The official orders provide earlier checkpoints, not an update to the October 2026 reporting. On October 9, 2025, the Supreme Court recorded a separate investigation, FIR 658/2025, after a complaint alleging threats to a witness. It noted that the investigation was ongoing and sought a further status report. On December 11, 2025, the Court said relevant witness statements had been recorded and a forensic report was awaited. The orders do not establish that a threat occurred.

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At the December 11 hearing, the State’s senior additional advocate general said 789 trials were pending before the same presiding officer. That was counsel’s submission recorded by the Court on that date, not an independently audited or current caseload figure.

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What the contrast does—and does not—show

On the figures reported October 3, 2026, FIR 220/2021 had reached the stage of final arguments, while FIR 219/2021 still faced a contested witness-and-prosecutor issue and renewed oversight. The status reports do not establish why the two cases progressed at different rates, and the witness counts alone do not determine the eventual outcome of either trial.

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FIR 219/2021FIR 220/2021India courtsLakhimpur KheriSupreme Court of Indiatrial updates

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