[ Court Doc ]   Acquittal >> Criminal Law   |   Murder Homicide >> Criminal Law  

The Supreme Court of India, on June 4, 2025, delivered a significant judgment in the case of Vaibhav v/s The State of Maharashtra, overturning the murder conviction of an individual, Vaibhav, who had been accused of killing his friend, Mangesh. The ruling, delivered by Justices B.V. Nagarathna and Satish Chandra Sharma , highlighted the critical importance of a complete chain of circumstantial evidence and the need for courts to consider plausible alternative theories, even when an accused's subsequent conduct raises suspicion.

The Fateful Day and Initial Investigation:

The case revolves around the death of Mangesh, a first-year homeopathy student at Bagla Homeopathy Medical College, Arvat Chandrapur, Maharashtra. On September 16, 2010, Mangesh and his friend Vaibhav, both fellow students, commuted together on Mangesh's scooter. They had tea and later arrived at Vaibhav's house. When Mangesh's father (PW-1) discovered his son had not returned home late that evening, he lodged a missing report. The following day, Mangesh's dead body was discovered, leading to a criminal case being registered.

Investigation soon pointed suspicion towards Vaibhav, leading to a chargesheet alleging he caused Mangesh's death by shooting him with his father's service gun.

Trial Court and High Court Proceedings:

The Trial Court found Vaibhav guilty of murder under Section 302 IPC, destruction of evidence under Section 201 read with Section 34 IPC, and offenses under the Arms Act. It concluded that Vaibhav killed Mangesh with his father's gun, then called friends Vishal and Akash (a juvenile) to help dispose of the body. Vishal was also found guilty of destruction of evidence.

Both Vaibhav and Vishal appealed to the Bombay High Court. The High Court upheld Vaibhav's conviction but acquitted Vishal due to lack of evidence. The High Court's decision primarily relied on circumstantial evidence, particularly Vaibhav's conduct after Mangesh's death. The High Court emphasized that Vaibhav attempted to stifle the investigation by removing evidence, such as the dead body and concealing clothes, and pretending to inquire about Mangesh with his father. It also noted Vaibhav's admission that the 9mm pistol belonging to his father caused Mangesh's death , and his inconsistent statements, such as claiming he found Mangesh with the pistol and immediately put it back where his father usually kept it, despite previously stating he didn't know where the pistol was.

The High Court dismissed Vaibhav's defense, which included arguments about the bullet's trajectory suggesting an accidental death and the inconclusive opinion of the medical expert (PW-9). The High Court reasoned that it was not obligatory for PW-9 to give an opinion on the cause of death since it was "admitted by the accused on oath".

The Supreme Court's Critical Re-evaluation:

Vaibhav appealed the High Court's judgment to the Supreme Court. His counsel argued that the High Court failed to properly examine crucial aspects of the defense. Key arguments included:

• Bullet Trajectory: PW-9's evidence indicated the bullet exited from the lower part of Mangesh's skull and then hit a ventilator significantly higher than Mangesh's height. The defense argued this trajectory was consistent with accidental or suicidal death, where Mangesh might have been looking downwards into the gun, and not homicidal.
• Inconclusive Medical Opinion: PW-9 explicitly stated she could not ascertain whether the death was accidental or homicidal , a point the High Court dismissed.
• Absence of Motive: The defense highlighted that Vaibhav and Mangesh were friends, and there was no apparent motive for Vaibhav to commit the murder. In cases based on circumstantial evidence, the absence of motive assumes significant importance and can weigh in favor of the accused.
• Burden of Proof: The defense contended that the courts below erroneously shifted the burden of proof onto Vaibhav to explain certain circumstances, whereas it is the prosecution's primary duty to prove its case beyond reasonable doubt.

The Supreme Court, while acknowledging that certain facts were admitted – such as Mangesh being shot by Vaibhav's father's pistol in Vaibhav's house , and Vaibhav's removal of the dead body and cleaning of the crime scene – found critical "missing links in the chain of the prosecution."

The Court found that the prosecution failed to explain the upward trajectory of the bullet after it exited Mangesh's skull, a fact strongly supporting the defense's theory of an accidental firing. The Court noted that the High Court had merely "brushed aside" this defense by focusing on Vaibhav's subsequent conduct.

Furthermore, the Supreme Court disagreed with the High Court's assertion that Vaibhav had "admitted" the death was homicidal. On the contrary, Vaibhav consistently maintained that the death was accidental.

The Verdict and Implications:

The Supreme Court concluded that the High Court erred in its finding of guilt, stating that "the circumstantial evidence on record is not consistent and leaves a reasonable possibility of an alternate outcome i.e. of innocence of the appellant on the charges of murder and illegal usage of fire arm." While Vaibhav's subsequent actions of cleaning the crime scene and making false inquiries raised suspicion, the Court reiterated that "mere suspicion, no matter how grave, cannot take the place of proof in a criminal trial."

The Court held that Vaibhav's conduct, while punishable (as destruction of evidence), was "quite natural" for a young man scared by an accidental death involving his father's gun in their home. Such conduct, the Court stated, cannot be the sole basis for a murder conviction without additional supporting evidence consistent with that conclusion.

Consequently, the Supreme Court partially set aside the High Court's judgment. Vaibhav was acquitted of murder under Section 302 IPC and offenses under the Arms Act. His conviction under Section 201 IPC (for causing the disappearance of evidence) was sustained, and he was sentenced to the period already undergone.

This judgment reaffirms the stringent standards for proving guilt in cases based on circumstantial evidence, underscoring that every link in the chain of circumstances must be complete and exclude any reasonable hypothesis of innocence. It also highlights the importance of courts thoroughly examining all aspects of a defense, rather than relying solely on inconsistencies in the accused's statements or subsequent conduct. 

  Section 201., Indian Penal Code - 1860  

  Section 302., Indian Penal Code - 1860  

  Indian Penal Code, 1860