PRESUMPTION CANNOT REPLACE PROOF: SUPREME COURT ON THE LIMITS OF CIRCUMSTANTIAL EVIDENCE IN CRIMINAL TRIALS

The Hon’ble Supreme Court, in the case of Vaibhav v. State of Maharashtra (Criminal Appeal No. 1463 of 2012, decided on 04.06.2025), acquitted a student previously convicted of murdering his friend, holding that the prosecution had failed to establish a complete and credible chain of circumstantial evidence. The case, which relied primarily on the Accused’s post-incident conduct—such as concealing the body and cleaning the blood-stained floor—was deemed insufficient to sustain a conviction. The Bench comprising Justices B.V. Nagarathna and Sanjay Kumar Sharma accordingly allowed the Appeal in part.

 

BRIEF FACTS

The case arose from a tragic incident involving two first-year students at Bagla Homeopathy Medical College in 2010—Vaibhav (the Appellant) and Mangesh (the Deceased). Mangesh had visited Vaibhav’s residence, following which his lifeless body was discovered the next day. It was alleged that Vaibhav had fatally shot Mangesh using his father’s service revolver, who was serving as a police officer. The prosecution claimed that following the shooting, Vaibhav attempted to conceal the crime by cleaning the blood-stained floor and hiding the body.

 

The Trial Court convicted Vaibhav for offences punishable under Sections 302 and 201 read with Section 34 of the Indian Penal Code, 1860, as well as under Section 5 read with Section 25(1)(a) of the Arms Act, 1959. His defence throughout was that Mangesh had accidentally shot himself while handling the pistol. Both the conviction and life sentence were upheld by the High Court.

 

ISSUES BEFORE THE COURT

The Supreme Court was called upon to examine:

1. Whether the prosecution had succeeded in establishing a complete and cogent chain of circumstantial evidence proving the guilt of the Appellant beyond reasonable doubt?

 

2. Whether the subsequent conduct of the Accused, including cleaning the crime scene and concealing the body, could independently establish guilt under Section 302 IPC?

 

3. Whether the absence of motive and the trajectory of the bullet supported the theory of accidental death?

 

4. Whether the Accused’s failure to offer an adequate explanation could shift the burden from the prosecution?

 

REASONING BEHIND THE JUDGMENT

The Hon’ble Court allowed the Appeal in part, setting aside the conviction for murder while upholding the finding under Section 201 IPC (causing disappearance of evidence). The key reasons for the Court’s decision included:

 

Failure to Establish the Actus Reus: The prosecution failed to prove the most fundamental fact—who pulled the trigger. Without proving this, the Court held, the conviction for murder could not be sustained.

 

Post-Crime Conduct Is Not Conclusive: While Appellant’s conduct in hiding the body and cleaning the scene may be punishable under Section 201 IPC, such acts could not alone prove murder. The Court held that the Accused’s subsequent conduct could only be considered after the prosecution had discharged its primary burden.

 

Inconsistencies in Prosecution’s Theory: The Court found internal contradictions in the prosecution’s narrative and a lack of reliable forensic corroboration. The medical evidence, particularly the bullet trajectory, was more consistent with the theory of accidental death than with intentional homicide.

 

Burden of Proof and Section 106 of the Evidence Act: The Court underscored that the Accused’s failure to offer an explanation for certain facts within his special knowledge, as contemplated under Section 106 of the Indian Evidence Act, 1872, does not discharge the prosecution from its foundational burden to prove guilt beyond reasonable doubt.

 

Absence of Motive: The prosecution failed to establish any motive, which, although not indispensable, is a crucial factor in cases based purely on circumstantial evidence.

 

ANALYSIS

This Judgment is a restatement of two deeply entrenched principles in criminal law: (i) the burden of proof always lies on the prosecution, and (ii) circumstantial evidence must form a complete and unbroken chain pointing only to the guilt of the accused.

 

The Court rightly rejected the prosecution’s reliance on Section 8 of the Indian Evidence Act to infer guilt from conduct alone, especially in the absence of direct evidence linking the accused to the act of shooting. The Judgment reaffirmed that even the strongest suspicion cannot substitute for legal proof. It emphasized that inferences drawn from the accused’s subsequent conduct must be approached with caution and can never supplant the prosecution’s fundamental duty to establish both the corpus delicti and the actus reus through cogent and admissible evidence.

Furthermore, the Court’s acknowledgement that the Appellant’s conduct may stem from fear, given his age and circumstances, reflects a nuanced understanding of human behaviour under stress. The distinction between moral suspicion and legal culpability is both fundamental and indispensable, yet frequently overlooked in cases influenced by public sentiment or emotional outrage.

 

CONCLUSION

The Supreme Court’s Judgment marks a reaffirmation of core principles of criminal jurisprudence: the presumption of innocence, the high threshold of proof in criminal trials, and the rigorous standards applicable to circumstantial evidence. It underscores the inadmissibility of drawing adverse inferences solely from the accused’s silence or post-occurrence conduct, and reaffirms that the prosecution bears the burden of establishing every constituent element of the offence beyond reasonable doubt.

 

By acquitting the Appellant of the charge of murder while holding him accountable for causing disappearance of evidence, the Hon’ble Court has drawn a principled line between what is suspicious and what is legally sustainable. The Ruling serves as a vital precedent on the application and limits of circumstantial evidence in Indian criminal law.

 

SARTHAK KALRA

Senior Legal Associate

The Indian Lawyer & Allied Services

 

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