Suspicion, However Grave, Cannot Take the Place of Proof: Supreme Court Acquits Accused in Circumstantial Murder Case (2025)

Summary of the Case

• Case Name: Vaibhav v. The State of Maharashtra

• Citation: 2025 INSC 800

• Court: Supreme Court of India

• Date of Judgment: 4 June 2025

• Bench: Hon’ble Justice Satish Chandra Sharma and Hon’ble Justice B.V. Nagarathna

• Acts and Sections Involved:

  • Indian Penal Code, 1860: Sections 302, 201, read with Section 34

  • Arms Act, 1959: Section 5 read with Section 25(1)(a)

  • Indian Evidence Act, 1872: Section 8

  • Code of Criminal Procedure, 1973: Section 27

• Cited Judgments:

  • Anwar Ali v. State of Himachal Pradesh (2020) 10 SCC 166

  • Preeti Gupta v. State of Jharkhand (2010) 7 SCC 667

  • Suresh Chandra Bahri v. State of Bihar (1995 Supp (1) SCC 80)

  • Babu v. State of Kerala (2010) 9 SCC 189

  • Pannayar v. State of Tamil Nadu (2009) 9 SCC 152

  • Shivaji Chintappa Patil v. State of Maharashtra (2021) 5 SCC 626

  • Nandu Singh v. State of Madhya Pradesh (Criminal Appeal No. 285 of 2022)

Introduction

The Supreme Court’s decision in Vaibhav v. State of Maharashtra provides a significant commentary on the use of circumstantial evidence, the role of subsequent conduct, and the legal thresholds for conviction in criminal trials. It revisits established principles of burden of proof and the presumption of innocence, ultimately acquitting the appellant of charges under Section 302 IPC and the Arms Act, while sustaining conviction under Section 201 IPC.

Facts and Procedural History

Vaibhav and Mangesh, friends and first-year students at a medical college in Maharashtra, were last seen together on 16 September 2010. The next day, Mangesh was found dead, shot with a service pistol registered in the name of Vaibhav’s father, a police officer.

Vaibhav was accused of murdering Mangesh using the pistol and was convicted by the trial court under Sections 302 and 201 IPC, as well as under the Arms Act. His appeal to the Bombay High Court was dismissed. The Supreme Court, however, took a different view, examining the totality of circumstances and the standard of proof in criminal jurisprudence.

The High Court’s Reasoning

The High Court upheld the conviction primarily on the basis of circumstantial evidence and subsequent conduct, noting:

“The fact that the accused attempted to stifle the investigation is relevant under Section 8 of the Indian Evidence Act.”

The Court pointed to the fact that Vaibhav:

• Removed Mangesh’s dead body

• Cleaned the crime scene

• Pretended to search for Mangesh alongside his father

• Failed to offer plausible explanations for the events post-incident

While the High Court emphasised this conduct to infer guilt, it failed to fully engage with the possibility of an accidental death, which Vaibhav consistently asserted.

Medical Evidence: The Turning Point

The Supreme Court focused intently on PW-9’s medical evidence, especially the trajectory of the bullet. The prosecution had not produced a ballistic report, yet both Vaibhav and his father admitted that the pistol used was the one kept at home.

PW-9 confirmed the bullet:

• Entered through the eye

• Exited from the lower back portion of the skull

• Then hit a ventilator mounted above the door

This trajectory suggested the bullet travelled upward after exit, casting serious doubt on the theory of a downward, homicidal shot from a standing assailant.

“Such trajectory of the bullet could have been possible only if the deceased was sitting and looking downwards towards the barrel of the pistol from a close distance.”

This aligned closely with Vaibhav’s consistent defence that Mangesh may have accidentally discharged the weapon while examining it out of curiosity.

Recalibrating the Burden of Proof

The Supreme Court firmly reiterated that in a criminal trial, the burden always lies with the prosecution to prove its case beyond reasonable doubt.

“The inability of an accused to offer plausible explanation… would not automatically absolve the prosecution of its evidentiary burden.”

Here, the prosecution failed to address critical gaps:

• No clear motive was established

• No direct evidence linked Vaibhav to pulling the trigger

• No forensic analysis matched his fingerprints to the pistol

Despite these shortcomings, the lower courts drew adverse inferences from Vaibhav’s conduct before determining whether the prosecution had built a consistent and credible case.

Motive in Circumstantial Cases

One of the notable contributions of this judgment is the nuanced discussion on motive. The Supreme Court cited multiple precedents to underscore that:

“Absence of motive, although not conclusive, is a relevant factor which weighs in favour of the accused.”

It noted that both families testified to a cordial friendship between Vaibhav and Mangesh. The Court observed that if enmity had existed, Mangesh accompanying Vaibhav home would have itself been questionable. But in the context of a friendly relationship, such conduct was natural and not inherently suspicious.

On Destroying Evidence: Section 201 IPC

The only conviction that survived was under Section 201 IPC – for causing the disappearance of evidence. Vaibhav admitted to cleaning the floor and moving the body, albeit out of fear.

“The subsequent conduct of cleaning up the scene and restoring the living room... although punishable in law, does not become so unnatural that it could be made the basis to convict him for the commission of murder.”

The Court acknowledged the psychological state of a young, frightened student whose friend accidentally died in his home with a firearm belonging to his father. The subsequent acts, though suspicious, were not enough to bridge the evidentiary gap in the prosecution's case.

Circumstantial Evidence and Alternate Theories

At the heart of the Court’s reasoning lies the chain of circumstances test. The Bench held:

“Suspicion, however grave, cannot take the place of proof... The theory put across by the appellant is fairly probable and is supported by medical evidence.”

In a case wholly reliant on circumstantial evidence, every link must be established. The moment a plausible alternate theory arises—such as an accidental discharge—the chain is deemed broken. This principle has been reaffirmed through decades of precedent.

Final Verdict

The Supreme Court concluded that:

• Conviction under Section 302 IPC and Section 5 read with 25(1)(a) of the Arms Act must be set aside.

• Conviction under Section 201 IPC (destruction of evidence) is upheld, but since Vaibhav had already undergone sufficient custody, no further sentence was imposed.

Conclusion

The Vaibhav judgment exemplifies the rigour required in assessing circumstantial evidence. The Court's patient dissection of the bullet’s trajectory, its willingness to entertain a realistic defence, and its rejection of mere suspicion as proof reflect the deep-rooted constitutional commitment to fair trial and due process.

For practitioners, this ruling reaffirms:

• The presumption of innocence as a core principle

• The limited probative value of suspicious behaviour in the absence of hard evidence

• The essentiality of forensic and ballistic coherence in firearm-related cases

Above all, it reminds us that judicial discipline must resist moral panic, and that doubt—reasonable and well-founded—is not a weakness of our legal system, but its greatest strength.

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