This case is a tragic tale involving the mysterious death of Mangesh, a first-year student at Bagla Homoeopathy Medical College in Chandrapur, Maharashtra. His close friend and classmate, Vaibhav, was accused of murdering him using his father’s service pistol. The prosecution relied entirely on circumstantial evidence, alleging homicide, while the defense claimed the death was accidental.
The Supreme Court was tasked with re-evaluating the conviction for murder under Sections 302 IPC (now Section 103 of BNS) and 25(1)(a) of the Arms Act, upholding only the conviction under Section 201 IPC (now Section 238 BNS) for destruction of evidence.
Title of the Case: Vaibhav v. State of Maharashtra
Court: Supreme Court of India
Citation: 2025 INSC 800
Date of Judgment: June 4, 2025
Coram: Justice B.V. Nagarathna and Justice Satish Chandra Sharma
Factual Background
On 16 September 2010, Vaibhav and Mangesh were last seen together after college, riding Mangesh’s scooter. They stopped at a tea stall before heading to Vaibhav’s home. Mangesh never returned. His father, PW-1, lodged a missing person report the same evening. The next day, Mangesh’s body was discovered in the courtyard behind Vaibhav’s house.
The police investigation revealed that Mangesh had been shot in the eye with a 9mm pistol belonging to Vaibhav’s father, a police officer (PW-12). Vaibhav was charged under:
- Section 302 IPC (punishment for murder),
- Section 201 IPC (causing disappearance of evidence),
- Section 5 read with Section 25(1)(a) of the Arms Act.
The trial court convicted Vaibhav. His appeal to the Bombay High Court was dismissed. The matter then reached the Supreme Court.
High Court’s Reasoning
The High Court upheld the conviction primarily based on circumstantial evidence. It relied on a chain of conduct that included:
- Vaibhav being the last person seen with Mangesh;
- The pistol being kept in Vaibhav’s home under a mattress;
- Vaibhav’s inconsistent statements about how the pistol ended up in Mangesh’s hand;
- The unnatural behaviour of Vaibhav—removing the body, cleaning the bloodstains, and making deceptive visits to Mangesh’s family;
- Admissions by Vaibhav that he had cleaned up the scene due to fear of his father.
The High Court considered these acts under Section 8 of the Indian Evidence Act (now Section 6 of the BSA) as conduct indicating guilt. It held that, despite no direct evidence, the circumstantial evidence formed a complete and unbroken chain pointing to guilt.
Appellant’s Arguments in the Supreme Court
Counsel for Vaibhav argued the following:
- Trajectory of the Bullet: Medical testimony (PW-9) revealed the bullet entered through the eye and exited from the back of the skull, but then hit a ventilator placed high above the door. This trajectory was inconsistent with a downward shot typical of homicide and suggested an accidental self-inflicted shot from a close range.
- No Motive: There was no established motive. Vaibhav and Mangesh were close friends, and no evidence suggested enmity.
- Admissions Out of Fear: Vaibhav’s actions—removal of the body and cleaning—were due to fear of his father, not indicative of guilt. His explanation should not be used to shift the burden onto him.
- Medical Evidence Ignored: The courts below failed to properly evaluate medical evidence, including PW-9’s neutral stance on whether the death was accidental or homicidal.
- Prosecution’s Failure to Prove Guilt Beyond a Reasonable Doubt: The circumstantial chain was not conclusive. Two views were possible, and in criminal law, the benefit of doubt must go to the accused.
Supreme Court’s Analysis
The Court embarked on a thorough review of the record and delivered a nuanced judgment.
1. Uncontested Facts
- The fatal bullet came from Vaibhav’s father’s service pistol.
- The pistol was kept in their home.
- Vaibhav admitted to removing Mangesh’s body and cleaning the scene.
However, the key issue was whether the shooting was intentional or accidental, and more critically, who pulled the trigger.
2. Missing Forensic Links
- No ballistic report was filed.
- No fingerprints were matched to Vaibhav.
- There was no direct evidence of him pulling the trigger.
3. Medical Evidence and Bullet Trajectory
The Court gave weight to PW-9’s testimony and diagrams indicating:
- The bullet entered through the eye and exited from the lower part of the skull.
- After exiting, the bullet hit a high-placed ventilator.
This trajectory indicated that Mangesh was likely looking down at the pistol when it fired, suggesting an accidental discharge rather than a close-range shot by another.
4. Section 8 of the Evidence Act (Section 6 of the BSA): Conduct Analysis
While the High Court relied heavily on Vaibhav’s conduct post-incident (concealment, misleading behaviour), the Supreme Court observed:
- Section 8 does make such conduct admissible.
- But conduct alone cannot prove guilt unless the prosecution has first established a solid case.
- Vaibhav’s reactions could stem from fear and panic, not guilt.
5. Motive and Absence Thereof
The Court emphasised that in a circumstantial case, motive is relevant. The prosecution presented no motive for Vaibhav to kill his friend. This absence significantly weakened the chain of evidence.
Citing Anwar Ali v. State of Himachal Pradesh and Shivaji Patil v. State of Maharashtra, the Court reiterated that the absence of motive in such cases weighs in favour of the accused.
6. Benefit of Doubt and Alternate Theory
The Supreme Court highlighted that even if the prosecution’s version was plausible, an equally plausible alternate version offered by the defense (accidental firing) could not be ignored.
The Court reaffirmed the principle:
“When two views are reasonably possible, the one favouring the accused must be preferred.”
Conclusion and Final Verdict
The Court concluded that:
- The prosecution failed to conclusively prove that Vaibhav shot Mangesh.
- The medical evidence and the conduct of the accused did not unambiguously support the homicide theory.
- The alternative explanation (accidental death) was credible and consistent with forensic details.
Held:
- Conviction under Section 302 IPC (murder) and Section 25 of the Arms Act was set aside.
- Conviction under Section 201 IPC (disappearance of evidence) was upheld.
- Sentence for Section 201 IPC was restricted to period already undergone.
The Court said:
“In light of the foregoing discussion, we hereby conclude that the High Court has erred in arriving at the finding of guilt and in upholding the verdict of the Trial Court. 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 firearm.”
Significance of the Judgment
This ruling is a significant reaffirmation of foundational principles in criminal jurisprudence:
- Burden of Proof: The prosecution must establish guilt beyond a reasonable doubt.
- Value of Medical Evidence: Forensic inconsistencies cannot be brushed aside in favour of behavioural analysis alone.
- Importance of Motive in Circumstantial Evidence: The absence of motive weakens the case in a circumstantial setup.
- Benefit of Doubt: Courts must lean toward the accused if an alternative, probable explanation exists.
The Supreme Court has also sent a clear message about judicial discipline in cases based on circumstantial evidence: Courts must not leap to conclusions solely on suspicious conduct; they must critically evaluate scientific and medical facts, especially when the accused offers a consistent defense aligned with such evidence.