Absence Of Motive No Ground For Acquittal When There Exists Strong Circumstantial Evidence : Supreme Court

The Supreme Court observed that the absence of motive will not be fatal to the prosecution's case if there exists strong circumstantial evidence proving the guilt of the accused beyond a cavil of doubt.

The Court said that “when the circumstances are very convincing and provide an unbroken chain leading only to the conclusion of guilt of the accused and not to any other hypothesis; the total absence of a motive will be of no consequence.”

In other words, motive loses importance when there's direct evidence proving guilt, the Court said.

“Motive is a very important link in the circumstances which could prove the guilt of the accused, and it loses its importance only when there is direct evidence of eyewitnesses, which is convincing and conclusive as to the guilt of the accused. However, it was also noticed that even if there may be a very strong motive for the accused to commit a particular crime, it does not lead to a conviction by itself, if the eyewitnesses are not convincing or the chain of circumstances is not complete.”

Holding thus, the bench comprising Justices Sudhanshu Dhulia and K Vinod Chandran upheld the conviction of a father, who murdered his son with a licensed revolver in the intervening night, when all other family members were sleeping.

Background

The Appellant-accused was the first to discover his son's body and falsely claimed that the death was a suicide caused by a screwdriver, an object that was later found to bear no bloodstains. Additionally, gunshot residue (GSR) was detected on the Appellant's right hand, his dominant hand, indicating that he had fired the weapon from close range, thereby undermining the suicide theory and supporting the prosecution's version of events.

In his defence, the Appellant argued that his son had taken his own life using the licensed gun and sought acquittal on the basis that there was no apparent motive for him to murder his son. He contended that the prosecution had failed to establish any clear motive for the alleged crime.

Despite these claims, the Trial Court found the Appellant guilty of murder and sentenced him to life imprisonment. This conviction was subsequently affirmed by the High Court.

The Appellant then challenged the decision by filing an appeal before the Supreme Court.

Observation

Affirming the impugned decision, the judgment authored by Justice Chandran noted that while the prosecution did not establish a clear motive, the Court held that strong circumstantial evidence can suffice even in the absence of motive.

In other words, in a case based on circumstantial evidence, proof of motive would 'supply a link in the chain of circumstances' but all the same, absence of motive cannot be a ground to altogether reject the prosecution case, as held in Suresh Chandra Bahri v. State of Bihar, 1995 Supp (1) SCC 80.

“Motive remains hidden in the inner recesses of the mind of the perpetrator, which cannot, oftener than ever, be ferreted out by the investigation agency. Though in a case of circumstantial evidence, the complete absence of motive would weigh in favour of the accused, it cannot be declared as a general proposition of universal application that, in the absence of motive, the entire inculpatory circumstances should be ignored and the accused acquitted.”, the court said.

Decision

Applying the above legal principles, the Court rejected the Appellant's claim that his son had committed suicide with his gun. It observed that the firearm had been in the Appellant's exclusive custody and that he alone knew how to operate it, which was further supported by the prosecution witnesses.

“In the present case, the accused and the deceased along with the wife of the accused and his two other children were residing in the house which was the scene of occurrence. The wife and two daughters were sleeping in another room, and they woke up hearing the shouts of the accused, who first detected the body. They came out and saw the youngest child lying in a pool of blood and one of the daughters summoned the neighbours. The family members and the neighbour who were examined before Court spoke of the accused having tried to convince them that it was a suicide by a self-inflicted injury; found to be a deliberate falsehood. The accused does not say what led him to the body at the dead of the night, when all were asleep. The accused admitted that he owned the gun, but his explanation was that it was hidden by his children, which is not plausible in the teeth of the corroborated deposition of PW-1, 3 & 4 that it was in the custody of the husband and that only he could use it.”, the court observed.

“Motive is not imperative, if there are very strong circumstances pointing to the guilt of the accused and the evidence of the family members clearly indicates the wayward ways of the accused and that he did not maintain good relations with his wife and children.”, the court noted.

Case Title: SUBHASH AGGARWAL Versus THE STATE OF NCT OF DELHI

Citation : 2025 LiveLaw (SC) 443

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Appearance:

For Petitioner(s) Mr. Varun Dev Mishra, AOR Ms. Mrinmoi Chatterjee, Adv. Ms. Kirti Lal, Adv.

For Respondent(s) Mr. Vikramjeet Banerjee, A.S.G. (NP) Mr. Mukesh Kumar Maroria, AOR Mr. Vijay Awana, Adv. Mr. Pratap Venugopal, Adv. Mr. Bhakti Vardhan Singh, Adv. Mr. P V Yogeswaran, Adv. Ms. Aakanksha Kaul, Adv.