“Suspicion, However Grave, Cannot Take the Place of Proof”: Supreme Court Acquits Student in Circumstantial Murder Case

Case Summary

• Case Title: Vaibhav v. State of Maharashtra

• Court: Supreme Court of India

• Citation: 2025 INSC 800

• Date of Judgment: 4 June 2025

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

• Appellant: Vaibhav

• Respondent: State of Maharashtra

• Advocates: Names not mentioned explicitly in judgment

• Acts and Sections Involved:

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

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

  • Indian Evidence Act, 1872 – Sections 8 and 27

• Cited Judgments:

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

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

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

  • State of U.P. v. Kishanpal (2008) 16 SCC 73

  • Pannayar v. State of T.N. (2009) 9 SCC 152

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

  • Nandu Singh v. State of M.P. (now Chhattisgarh), Criminal Appeal No. 285 of 2022

    
    

Introduction

The recent Supreme Court ruling in Vaibhav v. State of Maharashtra has provided significant jurisprudential guidance on criminal trials based on circumstantial evidence, especially where the nature of death is disputed—accidental, suicidal, or homicidal. This judgment meticulously evaluates the foundational standards of burden of proof, admissibility under the Evidence Act, and the role of medical and ballistic evidence in such cases.

Factual Matrix and Lower Court Findings

The appellant, Vaibhav, a first-year student at Bagla Homeopathy Medical College, was convicted by the Trial Court and the Bombay High Court for the alleged murder of his friend Mangesh. It was alleged that Vaibhav shot Mangesh using a 9mm service pistol belonging to his father, a police officer (PW-12), and attempted to dispose of the body with the help of juvenile accomplices. He was convicted under Sections 302, 201 IPC and Section 5 read with 25(1)(a) of the Arms Act.

While the Bombay High Court upheld the conviction under Sections 302 and the Arms Act, it acknowledged the circumstantial nature of the evidence and relied heavily on the appellant's conduct post-incident, invoking Section 8 of the Indian Evidence Act.

Supreme Court’s Analysis

The Hon’ble Justices meticulously dissected the evidentiary record and revisited the settled principles of law governing circumstantial evidence.

“In criminal jurisprudence, it is a time-tested proposition that the primary burden falls upon the shoulders of the prosecution…” — Hon’ble Justice Satish Chandra Sharma

The Hon’ble Court underlined the inviolable principle that the burden of proof lies upon the prosecution, which must be discharged beyond reasonable doubt. The appellant's inability to explain his conduct post-incident could not supplant the prosecution’s failure to establish a consistent and complete chain of events pointing towards guilt.

The Central Question: Who Pulled the Trigger?

This judgment revolves around the unanswered question—who actually pulled the trigger? The Supreme Court opined that although the death was caused by the pistol belonging to the appellant’s father and occurred at the appellant’s house, no concrete evidence existed to show that it was Vaibhav who fired the gun.

The Court noted:

“Despite two rounds of litigation, the question is yet to find an answer.” — Para 15 of the judgment

Key Evidentiary Gaps

Several elements raised significant doubts:

• Trajectory of the bullet: PW-9’s testimony and diagram indicated the bullet entered the eye and exited through the lower skull but then struck a ventilator installed above the door—a trajectory inconsistent with homicidal shooting.

• Absence of ballistic evidence: There was no forensic or ballistic report linking the weapon to the injury, although both appellant and PW-12 admitted the use of the latter’s service pistol.

• No fingerprint evidence: The prosecution failed to establish who had last handled the weapon.

“The prosecution version remains acceptable only till the point of entry of the bullet... it starts becoming cloudy when the upward trajectory of the bullet is analysed…” — Para 17

The Defence of Accidental Death

The appellant maintained that the death was accidental. According to him, Mangesh had picked up the pistol and accidentally pulled the trigger while examining it closely.

The Hon’ble Court found this explanation consistent with the medical evidence:

“The present case ticks the boxes of an accidental gunshot injury, both in theory and in fact.” — Para 20

This theory also explained the appellant’s nervous conduct in hiding the body and cleaning the scene due to fear of his father’s reaction.

Legal Standards and Burden of Proof

The Court reasserted the principle:

“The occasion to examine the version/defence of the appellant could have arisen only if the prosecution had succeeded in discharging its primary burden beyond reasonable doubt.” — Para 21

Importantly, the Court highlighted the asymmetry in evidentiary burdens:

• Prosecution: Prove guilt beyond reasonable doubt.

• Defence: Establish a plausible defence on a preponderance of probabilities.

  
  

Failure by the prosecution to meet its higher burden meant that the accused's version could not be dismissed merely because it was “improbable” or “incomplete.”

Role of Motive in Circumstantial Cases

Though motive is not always essential, its absence becomes critical in cases purely based on circumstantial evidence. In this case, the Court observed:

“The testimonies of prosecution witnesses have invariably revealed that the appellant and the deceased were friends and there was no ill-will between them.” — Para 25

Thus, the absence of motive significantly weakened the prosecution's case and created room for a reasonable alternative hypothesis.

The Court’s Verdict

The Hon’ble Bench acquitted the appellant of charges under Section 302 IPC and Section 5 read with 25(1)(a) of the Arms Act, stating that:

“The circumstantial evidence on record is not consistent and leaves a reasonable possibility of an alternate outcome...” — Para 29

However, it upheld the conviction under Section 201 IPC (causing disappearance of evidence) and sentenced him to the period already undergone.

Conclusion

This judgment is a significant reaffirmation of foundational criminal law principles—particularly the sanctity of the burden of proof and the standards required in cases reliant solely on circumstantial evidence. It also underscores the judiciary's cautious approach in interpreting post-incident conduct and reinforces the maxim:

“Suspicion, however grave, cannot take the place of proof.”

For legal professionals, Vaibhav v. State of Maharashtra serves as a salient precedent in assessing circumstantial evidence, the evidentiary burden on both sides, and the relevance of motive and medical testimony in homicide trials.