Institute of Legal and Management Studies

The Supreme Court on Friday (May 30) upheld the conviction of an individual accused of committing murder, noting that the prosecution's case rested on circumstantial evidence, where proof of motive need not be strictly proved, and the prosecution case cannot be discarded just because motive was not established.

The Court added that when the case rested on circumstantial evidence, then the prosecution need not prove the fact bereft of all doubts; rather what law contemplates is that for a fact to be considered proven, it must eliminate any reasonable doubt. In essence, the prosecution must dispel reasonable doubt, while proving the complete chain of events without any breakage leading to the conviction.

“Law does not require that a fact requires to be proved on absolute terms bereft of all doubts. What law contemplates is that for a fact to be considered proven, it must eliminate any reasonable doubt. Reasonable doubt does not mean any trivial, fanciful or imaginary doubt, but doubt based on reason and common sense growing out of the evidence in the case. A fact is considered proved if the court, after reviewing the evidence, either believes it exists or deems its existence probable enough that a prudent person would act on the assumption that it exists.”, the court observed.

“each of the circumstances from which certain inferences are sought to be drawn, is required to be proved in accordance with law, and there cannot be any element of surmise and conjecture, and each of these circumstances so proved must form a complete chain without any break to clearly point to the guilt of the accused person. The court has to examine the cumulative effect of the existence of these circumstances, which would point to the guilt of the accused, though any single circumstance may not in itself be sufficient to prove the offence. Thus, if the combined effect of all these circumstances, each of which has been independently proved, establishes the guilt of the accused, then the conviction based on such circumstances can be sustained. These circumstances so proved must be consistent only with the hypothesis with the guilt of the accused and should exclude every hypothesis except the one sought to be proved.”, the court added.

The bench comprising Justices Surya Kant and N. Kotiswar Singh heard the case where the Appellant was convicted for shooting the deceased, leading to his killing, based on the last seen theory, recoveries made pursuant to disclosure statements under Section 27 of the Evidence Act, and other circumstantial evidence.

The Appellant challenged the conviction, arguing that the prosecution failed to prove the motive for the commission of the crime; thus, in the absence of proof of motive, the conviction cannot be sustained.

The Prosecution, however, stated that the Appellant's motive behind the commission of the crime stating that the deceased's failure to repay the loan amount of Rs. 4,000/- and insulting the Appellant upon demand for money led to the killing of the deceased.

Affirming the conviction, the judgment authored by Justice N. Kotiswar Singh agreed to the prosecution's contention that there was an element of grudge against the deceased on the Appellant's part. However, on a different note, the Court said that even if there was no financial transaction involved between the Appellant and deceased, the same may not materially affect the Prosecution's case because the case rested on circumstantial evidence, which doesn't demand strict proof of motive.

The Court explained that proving one's motive is a difficult task, “as it remains hidden in the deep recess of the mind of the person concerned and in the absence of any open declaration by the person concerned himself, the motive has to be inferred from the activities and conduct of the person.”

“The law is now well-settled that while proof of motive certainly strengthens the prosecution case based on circumstantial evidence, failure to prove the same cannot be fatal.”, the court said, referring to G. Parshwanath vs. State of Karnataka 2010 (8) SCC 593.

Applying the aforementioned law, the Court found certain incriminating evidence against the Appellant such recovery of gun and empty pellets from the house of the appellant/his grandfather, which clearly indicates the involvement of the appellant as the same pellets and wads were recovered from the brain and skull of the deceased, that can be fired from the gun recovered at the Appellant's instance.

“The appellant's connection to the case deepened as various forensic and ballistic analyses were introduced. The recovery of the weapon and supporting evidence, including the corroborative testimonies of prosecution witnesses, established a compelling narrative. While motive is often challenging to substantiate, the chain of circumstantial evidence in this case continuously narrowed the focus toward the appellant's culpability. The scientific analysis of the gun and its discharged state, alongside the recovered empty pellets (from deceased's brain), played a critical role in aligning the timeline of events surrounding the crime.”, the court observed.

Silence Of Accused Towards Recovery Of Incriminating Evidence Strengthens Prosecution's Case

“It is true that even in cases based on circumstantial evidence, the prosecution cannot depend on the false alibi or unproven defence plea since the onus is always on the prosecution to prove the prosecution case and the onus never shifts to the accused. However, in such circumstances where prosecution has been able to prove on the basis of cogent evidence that the weapon of crime was traced to the accused, as in the present case, it was incumbent upon the appellant to explain the circumstances of the recovery of the weapon with which a linkage has been established with the injury suffered by the deceased through scientific evidence. However, apart from claiming ignorance and denying the various incriminating evidence presented during the trial, the appellant chose not to adduce any evidence to explain these circumstances. Thus, his silence and failure to explain any of the incriminatory circumstances, would strengthen the prosecution case based on circumstantial evidence against him as proved by the Prosecution.”, the court observed.

“In the present case, despite the incriminating evidence which has come up against him has been pointed out to him by the Court, he has not explained any of these but merely denied or feigned ignorance to which necessary inference can be drawn against him.”, the court added.

Conclusion

In terms of the aforesaid, the Court dismissed the appeal, noting that a clear pattern emerges out of the circumstances so proved with inferential and logical links which unmistakably points to the guilt of the appellant for committing murder of the deceased.

Case Title: CHETAN VERSUS THE STATE OF KARNATAKA

Citation : 2025 LiveLaw (SC) 657

Click here to read/download the judgment

Appearance:

For Appellant(s) : Mr. D.N.Goburdhun, Sr. Adv. Mrs. Rajani K Prasad, Adv. Ms. Abha R. Sharma, AOR

For Respondent(s) : Mr. Muhammad Ali Khan, A.A.G. Ms. Eesha Bakshi, Adv. Mr. Prashant Pratap Singh, Adv. Mr. Kamran Khan, Adv. Mr. V. N. Raghupathy, AOR