New Delhi, April 21, 2025 — The Supreme Court has reaffirmed that the absence of a clear motive does not necessarily undermine the prosecution’s case if strong circumstantial evidence proves the guilt of the accused beyond a reasonable doubt.
A bench comprising Justices Sudhanshu Dhulia and K. Vinod Chandran held that motive is not always imperative when there exists a chain of compelling circumstantial evidence that points directly to the accused’s guilt.
Court’s Observations
The Court observed that in cases where the circumstantial evidence forms a clear, unbroken chain leading to the only conclusion of the accused’s guilt, the absence of a motive is inconsequential.
“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,” the Court said.
Further, the Court stated:
“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, the Court also clarified that even a strong motive alone is not sufficient for a conviction if the circumstantial evidence or eyewitness testimony is not convincing. The Court emphasized that in the absence of motive, the chain of circumstantial evidence must remain intact to establish guilt.
Case Background
The case involves the conviction of a father, Subhash Aggarwal, who was found guilty of murdering his son with a licensed revolver during the night while the rest of the family was asleep. The appellant was the first to discover the body and initially claimed the death was a suicide caused by a screwdriver. However, this claim was disproved when no bloodstains were found on the screwdriver, and gunshot residue (GSR) was found on the appellant’s dominant hand, suggesting that he had fired the weapon from close range.
The appellant argued that his son had taken his own life using the family’s licensed gun, citing the lack of a clear motive for murder. Despite these claims, the trial court found him guilty of murder and sentenced him to life imprisonment. This conviction was upheld by the High Court.
Supreme Court’s Ruling
The Supreme Court, while rejecting the appellant’s defense, noted that although the prosecution could not establish a clear motive, the circumstantial evidence provided a solid case for conviction. The Court referred to previous rulings, including Suresh Chandra Bahri v. State of Bihar (1995), which reaffirmed that in cases based on circumstantial evidence, the absence of motive cannot automatically result in acquittal.
Justice K. Vinod Chandran, writing for the bench, noted:
“Motive remains hidden in the inner recesses of the mind of the perpetrator, which cannot often be ferreted out by the investigating agency. Though the absence of motive can weigh in favor of the accused in a case of circumstantial evidence, it cannot be universally applied to reject the prosecution’s case.”
Key Evidence
The Court pointed to several crucial factors that led to the conviction:
- The appellant had exclusive custody of the firearm and was the only one who knew how to operate it.
- The appellant initially misled family members and neighbors by claiming the death was a suicide.
- Eyewitness testimony indicated that the appellant’s behavior was suspicious, and his explanations were inconsistent.
- The appellant failed to provide a convincing explanation as to why he discovered the body at night, while the rest of the family was asleep.
The Court also noted that the appellant’s strained relationship with his family, especially his wife and children, pointed toward the possibility of foul play, even in the absence of a clear motive.
“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 remarked.
CASE DETAILS:
Case Title: Subhash Aggarwal v. State of NCT of Delhi
Citation: 2025 LiveLaw (SC) 443
Appearance:
For the Petitioner:
- Mr. Varun Dev Mishra, AOR
- Ms. Mrinmoi Chatterjee, Adv.
- Ms. Kirti Lal, Adv.
For the Respondent:
- Ms. Aakanksha Kaul, Adv.
- 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.
- P. V. Yogeswaran, Adv.
